Jacob Davis v. Tennessee Department of Correction

Syllabus

Having pursued relief under the Uniform Administrative Procedures Act, Jacob Davis filed a petition for a declaratory order with the Tennessee Department of Correction (\TDOC\ or \the Department\) to challenge the Department's interpretation of the statutes regarding release after a sentence of life, and the constitutionality of Tenn. Code Ann. § 40-35-501(i). Upon receiving an unsatisfactory response, Davis then filed a declaratory judgment action in the Davidson County Chancery Court against the TDOC and the Tennessee Attorney General (collectively, \the State\) about the calculation of his sentence, including his eligibility for release and the constitutionality of Tenn. Code Ann. § 40-35-501. The chancery court ruled against him and he appealed. The Court of Appeals finds, based on rules of statutory interpretation, Vaughn v. State, 202 S.W.3d 106 (Tenn. 2006), and a number of cases from the Court of Criminal Appeals, that Tenn. Code Ann. § 40-35-501(i) establishes the legal release date for someone sentenced to life. The court also finds that the statute is constitutional. The chancery court is affirmed.