Easley v. State
2017 Ark. App. 317
| Ark. Ct. App. | 2017Background
- Malcom Jalil Easley pleaded guilty on September 9, 2014, to hindering apprehension or prosecution (Class B felony) as part of a negotiated plea.
- Original sentence: ten years in the Arkansas Department of Correction (ADC) followed by ten years’ suspended imposition of sentence; credited with 554 days jail time served.
- State filed a petition to revoke the suspended sentence after Easley was implicated in an October 8, 2015 homicide; amended petition added allegations including felon-in-possession of a firearm and association with felons.
- At the revocation hearing, a detective testified that Easley admitted shooting the victim; the State verbally amended the petition to allege felon in possession of a firearm without objection; Easley presented no defense.
- Trial court found Easley violated the suspension conditions (possession of a firearm) and revoked the suspended sentence, sentencing him to ten years in the ADC and crediting him with 299 days jail time served awaiting revocation.
- Easley appealed solely arguing the ten-year post-revocation sentence was illegal because combined previous credit and sentence allegedly exceeded the statutory maximum for a Class B felony.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ten-year sentence after revocation was illegal | Easley: combined prior credited time and the new ten-year term exceed the statutory maximum for a Class B felony | State: court may impose any original-authority sentence so long as combined imprisonment does not exceed statutory maximum; revocation sentence here did not exceed the maximum | Court: sentence lawful; within trial court authority and did not exceed statutory maximum |
| Whether prior jail-time credit (554 days) must be applied to the post-revocation term | Easley: the 554 days credited against his original term should also reduce time available upon revocation | State: credit allocation argument does not render the sentence illegal and may not be raised first on appeal | Court: credit-allocation dispute does not make the sentence illegal and cannot be raised for first time on appeal |
Key Cases Cited
- Richie v. State, 357 S.W.3d 909 (Ark. 2009) (upholding that revocation court may impose any sentence originally available and that challenges to credit allocation do not necessarily constitute claims of illegal sentence)