CLARK v. FARRIS
2015 OK 62
| Okla. | 2015Background
- Clark sought both appellate and original jurisdiction review in this Court of a District Court order dismissing his habeas petition challenging his criminal judgment.
- The District Court dismissed Clark's habeas petition.
- Clark's filings in this Court sought civil appellate review of the District Court order.
- This Court applies the Dutton/ Powell framework, which limits civil appellate review of habeas petitions challenging criminal convictions.
- The Court assumes original jurisdiction solely to decide whether it has habeas jurisdiction to address Clark's claims.
- The Court dismisses Clark's appeal, assumes original jurisdiction in part and denies in part, and denies habeas relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Civil appellate jurisdiction over habeas order? | Clark seeks appellate review of the habeas order. | Dutton and Powell foreclose civil appellate jurisdiction in this context. | No civil appellate jurisdiction; appeal dismissed. |
| Original jurisdiction for habeas merits? | Clark seeks habeas relief under original jurisdiction. | Original jurisdiction not appropriate for merits, only jurisdictional questions. | Assumes original jurisdiction for jurisdictional determination; denies merits. |
Key Cases Cited
- Dutton v. City of Midwest City, 2015 OK 51 (OK Supreme Court (2015)) (limits civil appellate review of habeas petitions challenging criminal convictions)
- State of Oklahoma v. Powell, 2010 OK 40, 237 P.3d 779 (OK Supreme Court (2010)) (establishes standards for appellate review of habeas corpus in criminal cases)