J.Williams v. Kelley
2017 Ark. 200
Ark.2017Background
- Jackie Lee Williams was convicted on three separate rape charges in separate trials and received consecutive sentences (including life sentences); prior direct appeals affirmed each conviction.
- Williams filed a pro se habeas petition in the Jefferson County Circuit Court challenging jurisdiction, defects in the information (all counts under one case number), denial of fair trials, speedy-trial violations, and double-jeopardy violations.
- The circuit court dismissed the habeas petition, and Williams appealed the dismissal to the Arkansas Supreme Court.
- Williams had previously sought habeas relief and a petition to correct an illegal sentence; those efforts were denied and affirmed by this court.
- Williams did not invoke Act 1780 (actual-innocence pathway) and did not make the statutory showing of probable cause required for habeas relief based on facial invalidity or lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Defective information / joinder and case-number assignment | Williams argued the information was defective and joining all three charges under one case number deprived him of due process and jurisdiction | State argued joinder was permitted under Rule 21.1(a) and severance rules exist; any error is trial error not jurisdictional | Court held joinder/one case number claim is trial error, not jurisdictional; not cognizable in habeas |
| Speedy-trial violation | Williams claimed his speedy-trial rights were violated | State argued speedy-trial claims may be waived and are trial error | Court held speedy-trial claims are not cognizable in habeas proceedings |
| Double jeopardy from subsequent trials / multiple punishments | Williams asserted his multiple trials/punishments violated double jeopardy | State argued the offenses were distinct and separate so separate punishment is permissible; prior rulings rejected similar claims | Court held his double-jeopardy claim did not show facial invalidity or lack of jurisdiction and therefore is not cognizable; separate convictions for distinct crimes are permissible |
| Jurisdiction / facial invalidity of judgments | Williams contended the trial court lacked jurisdiction to impose two sentences because of defects in charging documents | State maintained the commitment and judgments were not facially invalid and court had jurisdiction | Court held Williams failed to allege facial invalidity or jurisdictional defect; habeas relief was not warranted |
Key Cases Cited
- Philyaw v. Kelley, 477 S.W.3d 503 (2015) (distinguishing jurisdictional defects from trial error for habeas review)
- Hobbs v. Gordon, 434 S.W.3d 364 (2014) (standard of review for postconviction and habeas relief)
- Turner v. State, 380 S.W.3d 400 (2011) (right to severance when offenses joined solely because of similarity)
- Clay v. State, 886 S.W.2d 608 (1994) (joinder of offenses of the same or similar character is permissible)
- Hinton v. State, 477 S.W.3d 517 (2015) (no constitutional barrier to separate punishment for distinct crimes)
- Williams v. State, 479 S.W.3d 544 (2016) (prior denial of petition to correct illegal sentence and discussion of double-jeopardy claim)
Affirmed.