ANARIAN CHAD JACKSON v. WENDY KELLEY, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION, 602 S.W.3d 743

In 2003 a Pulaski County jury convicted Anarian Chad Jackson of first-degree murder; he was sentenced to life and his conviction was affirmed on direct appeal.
Jackson filed a habeas petition in Lincoln County asserting the judgment was illegal because it was signed by Judge David Bogard, who did not preside at his trial (a special judge, Tim Fox, reportedly presided); he also alleged trial errors (admission of a pretrial statement) and judicial-bias/recusal issues based on threats.
The circuit court denied and dismissed the habeas petition for lack of merit and declined to hold an evidentiary hearing or appoint counsel; Jackson appealed pro se.
The Supreme Court reviewed whether the judgment was facially invalid or the trial court lacked jurisdiction (the narrow grounds for habeas relief when actual innocence is not alleged) and whether a hearing was required.
The majority held that jurisdiction attaches to the court/office (not the individual judge), so Judge Bogard—an elected judge of the judicial district—had authority to sign the judgment; evidentiary/admissions rulings and recusal claims are trial errors not cognizable in habeas; no probable cause was shown to require a hearing.
Justice Hart dissented, arguing Administrative Order No. 16 and constitutional procedures for appointing special judges and the requirement that the presiding judge sign orders could render the judgment facially suspect when those protocols aren’t shown to have been followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a judgment signed by a judge who did not preside is facially invalid / deprives trial court of jurisdiction	Jackson: Judgment is illegal because Judge Bogard did not preside; special judge Tim Fox presided and Bogard lacked authority to sign	State: Jurisdiction vests in the court/office; Bogard was an elected judge in the judicial district and had authority to sign	Held: Judgment not invalid on its face; jurisdiction rests with the court/office, not the individual judge; claim denied
Whether admission of a pretrial statement deprived court of jurisdiction	Jackson: Admission rendered the proceeding void	State: Evidentiary rulings are trial error and not a jurisdictional defect	Held: Admission challenge is trial error and not cognizable in habeas
Whether Judge Bogard’s alleged failure to recuse (bias) deprived court of jurisdiction	Jackson: Failure to recuse after threats meant judge lacked jurisdiction	State: Judicial-bias/recusal claims are trial error and do not strip jurisdiction	Held: Recusal/bias claims are not cognizable in habeas; no jurisdictional defect shown
Whether the circuit court erred by not appointing counsel and holding an evidentiary hearing	Jackson: Court should have appointed counsel and held a hearing on habeas claims	State: Hearing and appointment of counsel are not required absent a showing of probable cause for the writ	Held: Jackson did not show probable cause; no hearing or appointment required

Hobbs v. Gordon, 2014 Ark. 225 (standard of review for habeas-corpus denials)
Foreman v. State, 2019 Ark. 108 (habeas proper when judgment invalid on its face or trial court lacks jurisdiction)
Lukach v. State, 2018 Ark. 208 (jurisdiction attaches to the office/court, not the individual judge)
Simpson v. State, 310 Ark. 493 (court/office-based jurisdiction principles)
Waddle v. Sargent, 313 Ark. 539 (distinguished; addressed judges not elected in the judicial district)
Tilson v. Kelley, 2018 Ark. 128 (evidentiary-admission challenges not cognizable in habeas)
Jefferson v. Kelley, 2017 Ark. 29 (judicial-bias/recusal claims are trial error and do not deprive court of jurisdiction)
Sims v. State, 2018 Ark. 271 (no hearing required on habeas absent probable cause shown)
Jackson v. State, 359 Ark. 297 (direct-appeal affirmation of conviction)