Jason Ray v. Madison County, Tennessee

We accepted certification of questions of law from the United States District Court for the Western District of Tennessee, which require us to determine: (1) whether, for split confinement sentences, Tennessee law authorizes a sentencing court to fix a percentage of the sentence that a defendant must serve in actual confinement before becoming eligible to participate in a work program in the local jail or workhouse; and (2) whether Tennessee law imposes a duty on a sheriff to challenge an inmate’s improper or potentially improper sentence. We conclude (1) that for split confinement sentences Tennessee trial judges are authorized to fix a percentage the defendant must serve in actual confinement before becoming eligible to earn work credits; and (2) that sheriffs in Tennessee have no duty to challenge an inmate’s sentence as improper or potentially improper.