Leonard Noble v. State of Arkansas, 585 S.W.3d 671

In 1999 Leonard Noble was convicted by a Sebastian County jury of residential burglary and rape and, as a habitual offender, received an aggregate 900‑month sentence; the Arkansas Court of Appeals affirmed his conviction on direct appeal.
Noble filed a pro se petition for a writ of habeas corpus in the county where he was incarcerated, alleging (primarily) that the State violated his right to a speedy trial and arguing he was entitled to an evidentiary hearing.
The circuit court dismissed the habeas petition on the merits, concluding Noble had not been denied a speedy trial; the court also denied him a hearing.
The Supreme Court of Arkansas reviewed whether Noble had pleaded a cognizable ground for habeas relief under Ark. Code Ann. § 16‑112‑103(a)(1) and whether a hearing was required.
The majority held that speedy‑trial claims are not cognizable in Arkansas habeas proceedings because they assert trial error rather than facial invalidity of the judgment or lack of subject‑matter jurisdiction; because Noble failed to show probable cause for the writ, no hearing was required.
Noble’s later motion for leave to file a supplemental addendum in his reply brief was deemed moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether alleged speedy‑trial violation supports habeas relief	Noble: State's delay violated his right to a speedy trial and warrants relief	State: Speedy‑trial claims are trial‑error claims not cognizable on habeas; Noble did not plead a ground for writ	Held: Affirmed dismissal; speedy‑trial issues are not a basis for habeas relief because they do not show facial invalidity or lack of jurisdiction
Whether an evidentiary hearing was required on the habeas petition	Noble: He was entitled to a hearing to develop facts supporting his speedy‑trial claim	State: No probable cause shown in petition/affidavit; statute does not mandate a hearing without probable cause	Held: No hearing required because petitioner failed to show probable cause for issuance of the writ
Motion to file a supplemental addendum in reply brief	Noble: Sought leave to include supplemental material	State: Not argued in detail; court treated procedural motion after appeal	Held: Motion denied as moot

Philyaw v. Kelley, 477 S.W.3d 503 (Ark. 2015) (describing when writ of habeas corpus is proper)
Baker v. Norris, 255 S.W.3d 466 (Ark. 2007) (jurisdiction is the power to hear the subject matter)
Johnson v. State, 769 S.W.2d 3 (Ark. 1989) (trial court jurisdiction and personal jurisdiction necessary to render judgment)
Hobbs v. Gordon, 434 S.W.3d 364 (Ark. 2014) (standard of review for habeas dismissals)
Marshall v. State, 521 S.W.3d 456 (Ark. 2017) (appellate court may affirm correct result even if wrong reasoning used below)
Williams v. Kelley, 521 S.W.3d 104 (Ark. 2017) (held speedy‑trial issues not cognizable in habeas proceedings)
Stephenson v. Kelley, 544 S.W.3d 44 (Ark. 2018) (habeas will not correct trial errors or irregularities)
Jackson v. Norris, 378 S.W.3d 103 (Ark. 2011) (discussed by dissent and later addressed by U.S. Supreme Court)
Miller v. Alabama, 567 U.S. 460 (2012) (U.S. Supreme Court decision referenced by dissent)
Barker v. Wingo, 407 U.S. 514 (1972) (speedy‑trial analysis in a habeas context)
Eubanks v. Humphrey, 972 S.W.2d 234 (Ark. 1998) (speedy‑trial waiver discussion)