John Paul Seals v. State of Tennessee; Vikki Lynn Fritts Spellman v. State of Tennessee

Summary

The Tennessee Supreme Court affirmed the Court of Criminal Appeals, holding that the savings provision in Tenn. Code Ann. § 28-1-106 does not toll the one‑year post‑conviction statute of limitations, but that due‑process considerations may require tolling when a petitioner’s mental incompetence deprives him of a reasonable opportunity to present his claim. The court remanded for further proceedings on the tolling issue.