State of Tennessee v. Adrian R. Brown

Summary

The Court held that Tennessee Rule of Criminal Procedure 36.1 does not authorize correction of an illegal sentence after the sentence has expired, because the rule did not expand the scope of relief previously available through habeas corpus. It also held that failure to award pretrial jail credit does not make a sentence illegal or establish a colorable Rule 36.1 claim. The Court affirmed dismissal of the Rule 36.1 motion but remanded for correction of the judgments to reflect the three-year sentences accepted in the plea agreement.