Kelvin Collier v. Wendy Kelley, Director, Arkansas Department of Correction, 594 S.W.3d 50

Collier pleaded guilty in Jefferson County to first-degree murder, aggravated robbery, residential burglary, and theft; judgment and commitment filed May 8, 1997, imposing an aggregate 420‑month sentence.
He filed a pro se petition for writ of habeas corpus under Ark. Code Ann. § 16-112-101 alleging convictions were facially invalid because the judgments used an incorrect legal name (misnomer) across Jefferson, Bradley, and Desha County dockets.
Collier also argued the State knowingly used an alias, rendering pleas and service of process invalid and depriving the trial courts of jurisdiction; he did not seek relief under Act 1780 (actual‑innocence statute).
The circuit court dismissed and denied the petition for failing to show facial invalidity or lack of jurisdiction; Collier appealed pro se.
The Arkansas Supreme Court reviewed de novo the habeas standards and affirmed, holding Collier’s claims were trial‑error or due‑process/sufficiency issues not cognizable on habeas and that the misnomer did not render the judgments void on their face.

Issue	Collier's Argument	State's Argument	Held
Whether a misnomer (incorrect legal name on informations/judgments) renders convictions facially invalid/void for lack of jurisdiction	Misnomer is a "fatal misnomer" making judgments invalid on their face	Misnomer is a trial error; time to challenge was before trial/plea; does not show facial invalidity or lack of jurisdiction	Denied — misnomer is not facially invalidating; not cognizable in habeas
Whether pleas entered under an alias made the plea agreements void (involuntary/invalid contract)	Use of an alias meant Collier could not validly "contract" pleas, so convictions are invalid	Claims about plea validity are challenges to the plea proceeding and trial error, not a habeas basis; some arguments raised first on appeal	Denied — not properly raised for habeas; not cognizable here
Whether alleged actual innocence is a proper habeas ground	Asserts actual innocence of the offenses	Actual-innocence claims are effectively sufficiency or due‑process claims and are not cognizable on habeas absent Act 1780 relief	Denied — actual‑innocence/sufficiency claims not cognizable in habeas
Whether circuit court erred by dismissing for failure to attach certified judgments	Petition defective for lacking certified judgment copies	Court may affirm on other grounds without reaching this procedural defect	Not reached — affirmed on substantive grounds

Anderson v. Kelley, 2019 Ark. 6, 564 S.W.3d 516 (standard of review for habeas denial)
McArthur v. State, 2019 Ark. 220, 577 S.W.3d 385 (petitioner must plead facial invalidity or lack of jurisdiction absent Act 1780)
Philyaw v. Kelley, 2015 Ark. 465, 477 S.W.3d 503 (writ proper when judgment invalid on its face or court lacks jurisdiction)
Johnson v. Kelley, 2019 Ark. 230, 577 S.W.3d 710 (void/illegal sentence relates to trial court's authority to impose it)
Edwards v. Kelley, 2017 Ark. 254, 526 S.W.3d 825 (unless sentence illegal on its face, no showing of lack of jurisdiction)
Prince v. State, 304 Ark. 692, 805 S.W.2d 46 (alias or name variations should be challenged prior to trial/plea)
Mister v. Kelley, 2019 Ark. 187, 575 S.W.3d 410 (misnomer is trial error and not cognizable in habeas)
Stephenson v. Kelley, 2018 Ark. 143, 544 S.W.3d 44 (actual‑innocence claims treated as sufficiency/due‑process claims not cognizable on habeas)
Sanders v. Straughn, 2014 Ark. 312, 439 S.W.3d 1 (court addressed limits of misnomer challenges relied upon by Collier)
Rasul v. State, 2015 Ark. 118, 458 S.W.3d 722 (issues raised for first time on appeal are not addressed)