Harlon Finney v. Wendy Kelley, Director, Arkansas Department of Correction, 598 S.W.3d 26

In 2014, Harlon Finney pled guilty to second-degree murder and, as a habitual offender, received a 360‑month sentence.
Finney had a prior aggravated-robbery conviction (a violent felony) and later contended that this prior conviction affected his parole eligibility.
In 2019 Finney filed a pro se petition for a writ of habeas corpus in the county of his incarceration, claiming the Arkansas Department of Correction (ADC) miscalculated his parole-eligibility status and that the judgment was therefore void.
He argued he was unaware at the plea that his prior violent felony would require him to serve 100% of the sentence without parole under § 16‑93‑609(b)(1) and that the commitment order did not reference the parole bar statute.
The circuit court denied habeas relief; the Arkansas Supreme Court affirmed, holding parole-eligibility disputes and plea‑error claims are not cognizable in habeas and that Finney failed to show facial invalidity or lack of jurisdiction.
Justice Hart dissented, arguing Finney stated a viable claim (facial defect/conflict among parole statutes), that ambiguity should be resolved for the defendant, and that the matter should be remanded with counsel appointed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas corpus may be used to challenge parole eligibility/ADC’s parole calculation	Finney: ADC miscalculated parole eligibility; judgment void because parole bar not referenced on commitment order	Kelley/State: Parole eligibility is an executive/statutory determination and is not a proper habeas issue	Court: Denied — parole-eligibility challenges are not cognizable on habeas; relief limited to facial invalidity or lack of jurisdiction
Whether the commitment order is void on its face because it did not reference a parole‑bar statute (§ 16‑93‑609)	Finney: Commitment order’s failure to reference the parole bar renders judgment void and his detention unlawful	State: Parole-eligibility determinations do not enhance or modify the sentence; absence of statutory citation on the judgment does not make it void	Court: Denied — Finney failed to show facial invalidity; parole application does not change jurisdiction or sentence on its face
Whether claims of an involuntary or uninformed plea (or ineffective assistance) can be raised via habeas	Finney: He did not understand parole consequences when pleading guilty	State: Such claims are trial-error or postconviction matters and must be raised under Rule 37.1	Court: Denied — plea‑validity and ineffective-assistance claims are not proper in habeas; should be pursued by timely Rule 37.1 petition

Baker v. Norris, 369 Ark. 405 (2007) (jurisdiction defined and when court has authority to render judgment)
Crockett v. State, 282 Ark. 582 (1984) (a guilty plea is the defendant’s trial; plea challenges are not addressed in habeas)
Culpepper v. State, 268 Ark. 263 (1980) (defendant entitled to know effect of sentence)
Hales v. State, 299 Ark. 93 (1989) (penal statutes strictly construed and doubts resolved in favor of defendant)