CLARK v. FARRIS
2015 OK 62
| Okla. | 2015Background
- Clark filed in the Oklahoma Supreme Court seeking both civil appellate and original jurisdiction review of a District Court order.
- In the District Court, Clark sought a writ of habeas corpus to challenge his criminal judgment and sentence, which the District Court dismissed.
- This Court held that a District Court's habeas order against a criminal conviction is not reviewed under civil appellate jurisdiction when the relief challenges incarceration.
- The Court assumed original jurisdiction solely to determine whether it has habeas jurisdiction to address the merits of Clark's claims, not to decide merits under civil original jurisdiction.
- The Supreme Court dismissed Clark's appeal, assumed original jurisdiction in part and denied in part, and denied the petition for writ of habeas corpus.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there is civil appellate jurisdiction over Clark's habeas petition | Clark seeks appellate review of the District Court's order. | No civil appellate jurisdiction applies to habeas challenges to prior incarceration. | No civil appellate jurisdiction |
| Whether the Court should exercise original habeas jurisdiction on the merits | Clark seeks habeas relief on the merits of his conviction. | The case does not invoke civil original jurisdiction for merits review. | Original jurisdiction denied on merits |
| What is the scope of the Court's jurisdiction in this petition | To obtain relief addressing the criminal conviction. | Limit jurisdiction to determine habeas authority, not merits. | Assumed in part, denied in part |
Key Cases Cited
- Dutton v. City of Midwest City, 2015 OK 51 (OK Supreme Court 2015) (limits when habeas petitions seek civil appellate review of criminal convictions)
- State v. Powell, 2010 OK 40 (OK Supreme Court 2010) (distinguishes appellate vs. original jurisdiction in habeas contexts)