Hill v. State
2013 Ark. 413
| Ark. | 2013Background
- In 1995, Hill was found guilty by a Grant County jury of capital murder and sentenced to life without parole, a conviction this Court affirmed.
- Hill pursued various postconviction remedies with limited success prior to the 2012 filings in the Jefferson County Circuit Court, where he was incarcerated.
- On August 31 and October 2, 2012, Hill filed amended petitions and related pleadings including FOIA requests and motions for miscellaneous relief.
- The Jefferson County Circuit Court denied relief, and Hill timely appealed the denial and also sought to file a supplemental brief.
- This Court dismissed the appeal as moot, holding a habeas petition should not issue absent facial invalidity or lack of jurisdiction, and that many claims were not cognizable in habeas proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a habeas petition should issue when facial invalidity or lack of jurisdiction is not shown | Hill | State | Writ denied; no facial invalidity or lack of jurisdiction shown |
| Whether claims of trial errors and misconduct are cognizable in habeas proceedings | Hill | State | Not cognizable in habeas; regard as trial errors |
| Whether actual innocence claims or Act 1780 relief were properly pursued | Hill | State | Act 1780 relief not invoked; not proper in habeas petition |
| Whether FOIA requests for fingerprint analyses entitle relief at public expense | Hill | Gallagher/State | Not entitled to photocopying at public expense; no compelling need shown |
| Whether the circuit court’s denials and related orders should be reviewed or reversed | Hill | State | Appellate review of postconviction relief decisions not warranted absent clear error |
Key Cases Cited
- Hill v. State, 325 Ark. 419 (1996) (affirmation of conviction on direct appeal)
- Murphy v. State, 2013 Ark. 155 (2013) (habeas petitions require facial invalidity or lack of jurisdiction)
- Murry v. Hobbs, 2013 Ark. 64 (2013) (per curiam; procedures for habeas petitions)
- Roberson v. State, 2013 Ark. 75 (2013) (appeal from postconviction relief denied when unable to prevail)
- Tryon v. Hobbs, 2011 Ark. 76 (2011) (due process and prosecutorial misconduct concerns are trial errors, not habeas cognizable)
- Avery v. State, 2009 Ark. 528 (2009) (FOIA copying at public expense; compelling need standard)
- Friend v. Norris, 364 Ark. 315 (2005) (habeas relief not warranted for non-jurisdictional defects)