Ehler v. State
2015 Ark. 107
Ark.2015Background
- In 1995 Richard Ehler pleaded guilty to rape (Class Y felony) and was sentenced to 40 years’ imprisonment.
- In 2014 Ehler filed a pro se petition under Ark. Code Ann. § 16-90-111 claiming his 40-year sentence was illegal because it exceeded the Arkansas Sentencing Commission guidelines.
- The Baxter County Circuit Court denied and dismissed the petition; Ehler appealed pro se and also sought leave to file a belated reply brief (motion for rule on clerk).
- The State responded that the sentence was within the statutory range for a Class Y felony and therefore not illegal on its face.
- The Supreme Court reviewed whether the sentence was illegal on its face and whether the trial court could grant relief under § 16-90-111.
Issues
| Issue | Ehler's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Ehler’s 40‑year sentence is illegal because it exceeded the Sentencing Commission guidelines | The 40‑year term exceeded the guideline-presumptive sentence and so is illegal | The sentence is within the statutory range for a Class Y felony and thus legal | Affirmed: sentence not illegal on its face because it falls within statutory maximum/minimum |
| Whether § 16‑90‑111 authorizes collateral challenge at any time for a sentence illegal on its face | Ehler sought relief under § 16‑90‑111 as permitting such a challenge | State contended the court should deny because sentence is facially legal; court retained authority to hear facially illegal sentence claims under § 16‑90‑111 | Court: § 16‑90‑111 allows attack on facially illegal sentences at any time, but no relief here because sentence was within statutory limits |
Key Cases Cited
- Atkins v. State, 2014 Ark. 393, 441 S.W.3d 19 (illegal sentence is one illegal on its face; exceeds statutory maximum)
- Canada v. State, 2015 Ark. 8 (§ 16‑90‑111 retains authority to challenge facially illegal sentences at any time)
- Burton v. State, 367 Ark. 109, 238 S.W.3d 111 (statutory ranges govern over presumptive sentencing guidelines)
- Lovelace v. State, 301 Ark. 519, 785 S.W.2d 212 (definition of void/illegal sentence: illegal on its face)
- Grissom v. State, 2013 Ark. 417 (sentence within statutory limits is legal)
- Gilliland v. State, 2014 Ark. 149 (standard of review: trial court’s denial under § 16‑90‑111 reviewed for clear error)
Affirmed; motion to file belated reply brief moot.