Matthews v. Hobbs
2013 Ark. 381
Ark.2013Background
- In 1981 Dennis Ray Matthews pleaded guilty to capital murder and was sentenced to life without parole.
- In 2011 Matthews filed a pro se petition for a writ of habeas corpus in Jefferson County (where he was incarcerated), alleging he was insane/mentally incompetent when he pleaded guilty.
- Matthews claimed a pretrial mental evaluation had been ordered but not conducted and that the trial court never ruled on competency prior to judgment.
- The circuit court dismissed the habeas petition; Matthews appealed pro se to the Arkansas Supreme Court.
- The court considered whether Matthews’ allegations established facial invalidity of the judgment or lack of jurisdiction such that habeas relief was warranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether failure to conduct ordered pretrial mental evaluation or to rule on competency invalidates judgment or deprives court of jurisdiction | Matthews: He was insane/mentally incompetent at plea; lack of evaluation and ruling makes conviction illegal on its face and strips court of jurisdiction | Hobbs: Lack of mental-evaluation ruling does not render judgment facially invalid or deprive court of jurisdiction; issues available at trial/Rule 37 are not cognizable on habeas | Court: No. Failure to evaluate or rule did not deprive court of jurisdiction nor render judgment invalid on its face; habeas was improper |
| Whether habeas may be used to relitigate trial-stage issues or raise new claims not showing jurisdictional defect | Matthews: Sought relief based on competency and other alleged trial errors | Hobbs: Habeas is limited to facial invalidity or lack of jurisdiction; other claims are for trial or Rule 37 relief and cannot be raised first on appeal in habeas | Court: Habeas is not a substitute for Rule 37; may not raise trial errors or new claims first on appeal in habeas |
| Whether Matthews offered sufficient proof of incompetence to support habeas probable-cause showing | Matthews: Pointed to the ordered but unperformed evaluation; no further proof submitted | Hobbs: No affidavit or other evidence of probable cause was presented to show illegal detention | Court: Matthews failed to produce evidence or probable-cause showing; petition insufficient |
| Whether due-process allegations can be remedied in habeas | Matthews: Implied due-process deprivation from lack of competency determination | Hobbs: Due-process claims generally are not cognizable in habeas where no facial invalidity or jurisdictional defect shown | Court: Due-process allegations absent jurisdictional defect are not cognizable in habeas proceedings |
Key Cases Cited
- Girley v. Hobbs, 2012 Ark. 447 (habeas limited to facial invalidity or lack of jurisdiction)
- Abernathy v. Norris, 2011 Ark. 335 (same principle regarding habeas scope)
- Young v. Norris, 365 Ark. 219 (burden on petitioner to show lack of jurisdiction or facial invalidity)
- Henderson v. State, 2010 Ark. 30 (failure to conduct ordered mental evaluation does not deprive court of jurisdiction)
- Coleman v. State, 2011 Ark. 308 (a guilty plea constitutes the defendant's trial)
- Crockett v. State, 282 Ark. 582 (plea-related trial principles)
- Murry v. Hobbs, 2013 Ark. 64 (statutory requirement to plead facial invalidity or lack of jurisdiction and show probable cause)