Dennis Dykes, Appellant v. Billy Compton

Summary

The Tennessee Supreme Court held that the validity of an indictment and the efficacy of the resulting conviction may be challenged in a habeas corpus petition when the indictment is so defective as to deprive the trial court of jurisdiction, reversing the Court of Criminal Appeals only to the extent it held such challenges can never be raised in habeas. Applying the three-part test from State v. Hill, the court concluded that Dykes's aggravated rape indictment, though silent on culpable mental state, provided adequate notice, complied with Tenn. Code Ann. § 40-13-202, and permitted the mental state to be inferred from the conduct alleged, so the conviction was valid and the petition was properly dismissed.