Houston v. State, 2014 Ark. App. 344

Houston pled guilty to probation-revocation for residential burglary; probation revoked and petition filed December 18, 2012.
On April 2, 2013, Houston pled guilty to the probation-revocation petition and was sentenced to 12 years; sentencing order entered April 2, 2013.
Houston timely filed a notice of appeal on April 30, 2013; counsel filed an Anders brief; Houston submitted pro se points for reversal.
State concurs that the appeal should be dismissed for lack of jurisdiction or merit under Rule 1(a) and Rule 24.3(b).
Rule 1(a) generally bars appeals from guilty pleas; exceptions exist but do not apply here.
Court dismisses the appeal and grants counsel’s withdrawal; Hubbard v. State relied upon for dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the appeal is permissible after a guilty plea to probation revocation	Houston argues for appellate review of the revocation	State contends lack of jurisdiction; no applicable exception	Appeal dismissed for lack of jurisdiction

Johnson v. State, 2010 Ark. 63 (Ark. 2010) (evidentiary errors during sentencing post-plea may support appeal)
Reeves v. State, 339 Ark. 304, 5 S.W.3d 41 (Ark. 1999) (postjudgment motion to amend illegal sentence after guilty plea)
Hubbard v. State, 2012 Ark. App. 443 (Ark. App. 2012) (procedural dismissal for lack of jurisdiction)
Kelley v. State, 2012 Ark. App. 36 (Ark. App. 2012) (addresses preservation requirements for direct appeal)
Breeden v. State, 2013 Ark. 145 (Ark. 2013) (ineffective-assistance claim requires trial-level development)
Guevara v. State, 2012 Ark. 351 (Ark. 2012) (claims not raised below generally不可 addressed on direct appeal)
London v. State, 354 Ark. 313, 125 S.W.3d 813 (Ark. 2003) (preservation and procedural requirements for appeals)
Scroggins v. State, 2012 Ark. App. 87, 389 S.W.3d 40 (Ark. App. 2012) (voluntariness assertions must be preserved below)