Doyle Hart v. State of Tennessee

Summary

The Tennessee Supreme Court affirmed the denial of Doyle Hart's petition for habeas corpus relief, holding that neither of the two indictment counts under which he was convicted was void. Count 1 (aggravated rape) gave constitutionally sufficient notice despite omitting a culpable mental state, because under State v. Hill the mental state may be inferred from conduct alleging sexual penetration of a child under thirteen. Count 2 (incest) was valid even though it charged "carnal knowledge" rather than the governing statute's term "sexual penetration," because acts of carnal knowledge fall within the statutory definition of sexual penetration and the count complied with Tenn. Code Ann. § 40-13-202. No separate opinions were filed.