Benton v. State
2013 Ark. 385
| Ark. | 2013Background
- Appellant Gary W. Benton was convicted in 2010 by a jury of second-degree forgery and theft by receiving, sentenced as a habitual offender to 360 months' imprisonment.
- The Arkansas Court of Appeals affirmed his conviction on direct appeal (Benton v. State, 2012 Ark. App. 71, 388 S.W.3d 488).
- In 2013, Benton, incarcerated in Lee County, filed a pro se petition for writ of habeas corpus in the Lee County Circuit Court reiterating his trial- and direct-appeal arguments.
- The circuit court denied the habeas petition, and Benton appealed the denial to the Arkansas Supreme Court."
- The Supreme Court dismissed the appeal as moot, noting Benton could not prevail on habeas review where claims attacked trial outcomes rather than facial validity or jurisdiction.
- The court emphasized that habeas relief is proper only for facial invalidity or lack of jurisdiction, and that claims about trial error or evidentiary sufficiency are not cognizable in habeas proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the habeas petition was a proper vehicle to challenge the conviction. | Benton (Benton) argues alleged trial errors and evidentiary issues warrant relief. | State maintains habeas is improper for non-facial-invalidity or non-jurisdiction issues. | Not cognizable; dismissal affirmed. |
| Whether the petition presented facial invalidity or lack of jurisdiction. | Benton contends errors undermine validity or jurisdiction. | Claims did not show facial invalidity or lack of jurisdiction. | No basis for writ; petition fails on jurisdiction/facial validity requirement. |
| Whether Benton could prevail on appeal given the habeas record. | Arguments could have been raised on direct appeal. | Claims were not persuasive or procedurally proper in habeas context. | Appellate relief not available; dismissal affirmed. |
| Whether the circuit court had jurisdiction to entertain the habeas petition. | Court held mandate that jurisdictional defect not shown; petition dispositive not to issue writ. | ||
| Whether the appeal should be dismissed as moot. | Appeal dismissed as moot; motions moot. |
Key Cases Cited
- Roberson v. State, 2013 Ark. 75 (Ark. 2013) (per curiam; habeas relief not available for trial-error claims)
- Williams v. Norris, 2012 Ark. 30 (Ark. 2012) (per curiam; habeas relief not available for direct-appeal issues)
- Russell v. Howell, 2011 Ark. 456 (Ark. 2011) (per curiam; habeas relief not available for trial-error claims)
- Lukach v. State, 369 Ark. 475, 255 S.W.3d 832 (Ark. 2007) (per curiam; habeas relief limitations)
- Abernathy v. Norris, 2011 Ark. 335 (Ark. 2011) (per curiam; limits of habeas corpus)
- Davis v. Reed, 316 Ark. 575, 873 S.W.2d 524 (Ark. 1994) (habeas corpus standards)
- Young v. Norris, 365 Ark. 219, 226 S.W.3d 797 (Ark. 2006) (per curiam; show probable cause to believe detention illegal)
- Bliss v. Hobbs, 2012 Ark. 315 (Ark. 2012) (habeas proceedings do not relitigate trial merits)
- McHaney v. Hobbs, 2012 Ark. 306 (Ark. 2012) (habeas claims not cognizable for trial-error issues)
- Douthitt v. Hobbs, 2011 Ark. 416 (Ark. 2011) (per curiam; limits of habeas relief)
- Culbertson v. State, 2012 Ark. 112 (Ark. 2012) (jurisdictional considerations in habeas)
- Tryon v. Hobbs, 2011 Ark. 76 (Ark. 2011) (per curiam; jurisdictional matters)