Mark D. Archer, Petitioner-Appellant v. State of Tennessee, Respondent-Appellee

Summary

The Tennessee Supreme Court held that challenges to the voluntariness of guilty pleas generally cannot be pursued in state habeas corpus proceedings, because Tennessee habeas relief is confined to judgments that are void on their face for want of jurisdiction or authority or to expired sentences, whereas an allegedly involuntary plea renders a judgment voidable only. The Court affirmed dismissal of Archer's petition, which the trial court properly converted into a post-conviction petition and dismissed as untimely under the three-year limitations period of T.C.A. Sec. 40-30-102; applying that limitations period does not unconstitutionally suspend the writ under Article I, Section 15 of the Tennessee Constitution because legitimate habeas petitions remain unrestricted. The Court declined to decide whether an out-of-state prisoner has standing to seek a Tennessee writ.