Jefferson v. Kelley
2017 Ark. 29
| Ark. | 2017Background
- Wesley Jefferson, an Arkansas Department of Correction inmate, appealed the denial of his pro se habeas corpus petition filed in Lee County Circuit Court.
- Jefferson challenged his underlying convictions (capital murder, aggravated robbery, theft, fleeing) previously affirmed by this Court in Jefferson v. State.
- His habeas petition alleged illegal sentence, insufficient evidence/actual innocence, amended information improperly changing the charge, trial errors, ineffective assistance of counsel, prosecutorial misconduct, and judicial bias.
- Jefferson did not proceed under Act 1780 (the actual-innocence statute) and filed in Lee County though his conviction was in St. Francis County.
- The Supreme Court reviewed whether Jefferson alleged facial invalidity of the judgment or lack of trial-court jurisdiction—requirements for habeas relief absent Act 1780—and found he did not.
- The Court dismissed the appeal as meritless and denied motions as moot after Jefferson filed his brief.
Issues
| Issue | Plaintiff's Argument (Jefferson) | Defendant's Argument (Kelley/State) | Held |
|---|---|---|---|
| Whether habeas is available for claims of actual innocence/sufficiency of evidence absent Act 1780 | Jefferson claimed actual innocence and insufficient evidence | State argued actual-innocence/sufficiency claims are not cognizable in habeas absent Act 1780 and must be filed where conviction occurred | Held: Not cognizable in habeas here; Jefferson did not invoke Act 1780 and filed in wrong county |
| Whether ineffective-assistance claims are cognizable in habeas | Jefferson alleged multiple ineffective-assistance errors | State argued such claims require factual inquiry beyond facial validity and are not proper in habeas | Held: Ineffective-assistance claims are not cognizable in habeas proceedings |
| Whether allegations of prosecutorial misconduct, trial error, or judicial bias support habeas relief | Jefferson asserted misconduct, trial errors (including denial of motion to quash), and judicial bias | State argued these are trial-error claims that do not impugn facial validity or jurisdiction and belong on direct appeal or postconviction relief | Held: These claims are not within habeas scope and do not justify relief |
| Whether amendment of the information that changed manner (but not nature) of offense renders judgment facially invalid or deprives court of jurisdiction | Jefferson argued the amended information altered the nature/degree of capital-murder charge, rendering sentence illegal | State argued amendment changed only the manner, not the nature, so it did not affect jurisdiction or facial validity | Held: Amendment did not implicate jurisdiction or facial invalidity; claim treated as trial error and is not cognizable in habeas |
Key Cases Cited
- Jefferson v. State, 372 Ark. 307 (prior affirmance of convictions) (background on the underlying conviction)
- Philyaw v. Kelley, 2015 Ark. 465 (habeas proper only for facially invalid judgments or lack of jurisdiction)
- Early v. Hobbs, 2015 Ark. 313 (dismissal of meritless postconviction/habeas appeals)
- McConaughy v. Lockhart, 310 Ark. 686 (ineffective-assistance claims not cognizable in habeas)
- Sanders v. Straughn, 2014 Ark. 312 (defective-information claims that do not affect jurisdiction are trial error, not habeas)
- Murphy v. State, 2013 Ark. 155 (habeas review limited to facial validity of commitment)
- Fields v. Hobbs, 2013 Ark. 416 (no habeas relief absent showing of lack of jurisdiction or facial invalidity)