Hunt v. State
2016 Ark. 57
Ark.2016Background
- Stanley L. Hunt II was convicted by a Faulkner County jury of three counts of rape and sentenced to an aggregate 480 months; the Arkansas Court of Appeals affirmed.
- Sixty-one days after the court of appeals issued its mandate, Hunt filed a Rule 37.1 postconviction petition and, the same day, a petition seeking relief via writ of error coram nobis or, alternatively, writ of habeas corpus.
- The Faulkner County Circuit Court denied both petitions in a single June 19, 2015 order.
- Hunt appealed to the Arkansas Supreme Court and moved for extensions of time to file his appellate brief; he eventually tendered his brief.
- The Supreme Court reviewed the record and determined the trial court correctly denied relief for multiple independent procedural reasons, making reversal impossible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Timeliness of Rule 37.1 petition | Hunt contended his Rule 37.1 petition should be considered despite filing 61 days after the appellate mandate. | State argued Rule 37.2(c)(ii) requires filing within 60 days after mandate; untimely petitions cannot be granted. | Court held petition untimely; dismissal proper. |
| Coram nobis jurisdiction | Hunt sought coram nobis relief in circuit court without first obtaining reinvestment of jurisdiction from the Supreme Court. | State argued leave from this Court was required because the appellate record remained here. | Court held circuit court lacked authority to consider coram nobis absent leave; dismissal proper. |
| Habeas corpus venue | Hunt filed habeas in Faulkner County though he was incarcerated in Lincoln County. | State argued habeas must be filed in the county where prisoner is held unless proceeding under Act 1780. | Court held Faulkner County lacked authority to grant release; petition improperly filed and dismissed. |
| Appellate motions for time extension | Hunt moved for extensions to file his appellate brief. | State implicitly opposed delay; procedural mootness not argued. | Court dismissed the appeal as Hunt could not prevail; the extension motions were moot because he already tendered a brief. |
Key Cases Cited
- Wheeler v. State, 463 S.W.3d 678 (Ark. 2015) (affirmance and dismissal standard when appellant cannot prevail on postconviction appeal)
- Engram v. State, 430 S.W.3d 82 (Ark. 2013) (timeliness requirements for Rule 37 petitions)
- Noble v. State, 460 S.W.3d 774 (Ark. 2015) (coram nobis requires leave from Supreme Court where record remains in appellate court)
- Neely v. McCastlain, 306 S.W.3d 424 (Ark. 2009) (appellate court may affirm denial of postconviction relief even if trial court relied on wrong reason)