## Facts

- The defendant, Hicks, was charged in Tennessee criminal proceedings and ultimately entered a plea agreement to voluntary manslaughter.
- The plea bargain provided for a negotiated sentence described as “hybrid” in structure: the length of the sentence corresponded to a higher offender range (Range II), while the release eligibility percentage corresponded to a lower offender range (Range I).
- The trial court accepted the agreement and imposed the negotiated sentence consistent with the parties’ bargain.
- Hicks later sought post-conviction relief, arguing that the hybrid sentence was not authorized by Tennessee sentencing law and therefore was illegal or void.
- The post-conviction challenge focused on whether a court may impose a sentence with a Range II term length while applying Range I release eligibility when that configuration results from a negotiated guilty plea.
- The litigation posture required the reviewing courts to address the enforceability of the bargain against the background of statutory sentencing ranges, release eligibility rules, and the constitutional requirement that guilty pleas be knowing and voluntary.

## Issues

1. Whether a negotiated guilty plea may lawfully include a “hybrid” sentence that combines a Range II sentence length with Range I release eligibility.
2. Whether the existence of a sentence term or release-eligibility component arguably inconsistent with standard sentencing classifications renders the judgment illegal for post-conviction purposes.
3. Whether a defendant who knowingly and voluntarily accepts a negotiated hybrid sentence may obtain post-conviction relief on the theory that the sentence is unauthorized.

## Decision

- The Tennessee Supreme Court upheld the negotiated hybrid sentence and denied post-conviction relief.
- The court concluded that the negotiated sentence was lawful when imposed pursuant to a knowing and voluntary plea agreement.
- The court rejected the argument that the hybrid structure, standing alone, rendered the judgment void or subject to post-conviction correction.
- The court treated the defendant’s informed acceptance of the negotiated sentence as central to enforcing the plea bargain and to the validity of the resulting judgment.

## Legal Principles

- A guilty plea is valid only if entered knowingly, voluntarily, and intelligently; when that standard is met, negotiated sentencing terms generally will be enforced.
- A negotiated sentence may be upheld even if it does not mirror the default pairing of offender-range classification and release eligibility, so long as the agreement is accepted by the court and is not otherwise prohibited by law.
- Post-conviction relief is not available merely because a defendant later disputes a sentencing configuration that was explicitly negotiated and accepted as part of a valid plea.
- Courts give substantial weight to the finality of plea-bargained judgments when the defendant received the benefit of the bargain and the record shows an informed waiver of trial rights.

## Conclusion

The Tennessee Supreme Court held that a plea-bargained “hybrid” sentence combining a Range II term length with Range I release eligibility is enforceable where the defendant knowingly and voluntarily agreed to the arrangement, and it therefore affirmed denial of post-conviction relief.


Hicks v. State, 945 S.W.2d 706 (Tenn. 1997)