KNOX v. OKLAHOMA COURT OF CRIMINAL APPEALS
2017 OK 2
| Okla. | 2017Background
- Petitioner Antone Lamadingo Knox sought relief from his criminal conviction by filing a motion styled as writs of mandamus and prohibition, requesting vacation of his judgment and sentence plus oral argument and an evidentiary hearing.
- The Oklahoma Supreme Court construed Knox’s filings by substance as a petition for writ of habeas corpus to inquire into the legality of his detention.
- Knox named the Oklahoma Court of Criminal Appeals and its judges as respondents, alleging that that court’s rulings failed to grant him relief.
- The Supreme Court noted it lacks appellate jurisdiction over criminal convictions (exclusive appellate jurisdiction resides in the Court of Criminal Appeals).
- The Court assumed limited original jurisdiction only to determine whether it had jurisdiction to proceed, declined to take the case on the merits, and denied the petition for writ of habeas corpus.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proper characterization of petitioner’s filings | Knox treated his motion as mandamus/prohibition seeking vacatur, argument, and hearing | Court interprets by substance, not title, and treats it as habeas corpus | Court construed filings as a habeas corpus petition |
| Whether the Oklahoma Supreme Court has jurisdiction to review criminal convictions | Knox requested this Court not transfer the matter and sought review of his conviction | State/Respondents: Supreme Court lacks original jurisdiction over criminal convictions; Court of Criminal Appeals has exclusive appellate jurisdiction | Supreme Court lacks jurisdiction to adjudicate the merits and denied relief |
| Whether petition raises institutional-deficiency claim against the Court of Criminal Appeals | Knox alleged the Court of Criminal Appeals failed to grant relief | Respondents: Allegations do not show a legally cognizable institutional deficiency | Court held no cognizable institutional-deficiency claim was shown |
| Whether the Supreme Court should assume original jurisdiction on the merits | Knox implicitly requested relief in this Court | Respondents: Claims do not invoke civil original jurisdiction of this Court | Court assumed jurisdiction only to determine jurisdictional propriety and declined to rule on merits; petition denied |
Key Cases Cited
- Brooks v. Baltz, 12 P.3d 467 (Okla. 2000) (habeas corpus is a summary inquiry into legality of detention)
- Application of Caldwell, 525 P.2d 641 (Okla. 1974) (character of habeas corpus proceedings)
- State ex rel. Dept. of Transportation v. Cole, 236 P.3d 49 (Okla. 2009) (effect of pleading determined by substance, not title)
- State ex rel. Wright v. Oklahoma Corporation Commission, 170 P.3d 1024 (Okla. 2007) (substance-over-form in pleadings)
- Dutton v. City of Midwest City, 353 P.3d 532 (Okla. 2015) (Supreme Court lacks appellate jurisdiction in criminal cases; no institutional-deficiency shown)
- Clark v. Farris, 358 P.3d 932 (Okla. 2015) (assumption of original jurisdiction solely to determine jurisdictional propriety)