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Matthews v. State
2017 Ark. App. 25
| Ark. Ct. App. | 2017
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Background

  • Jackie Renay Matthews pled no-contest in 2012 to aggravated assault (Class D) and received 60 months’ probation.
  • The State filed multiple petitions to revoke Matthews’s probation for failures to report, update information, pay fines/costs, and complete anger-management/drug-treatment requirements.
  • Matthews admitted violations and signed revocation plea statements in 2013 and 2014, each resulting in continued probation terms.
  • A third revocation petition (filed December 2014) led to a 2016 revocation hearing; Matthews was sentenced to 36 months in the DOC with 24 months suspended.
  • Matthews appealed the revocation; appellate counsel filed a no-merit brief and moved to withdraw under Anders/Ark. Sup. Ct. R. 4-3(k), notifying Matthews of her right to file pro se points—she did not.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether Matthews may appeal from her guilty/plea-based revocation The State maintained the revocation and sentence were proper (no specific argument to overturn). Matthews offered no pro se points after counsel’s Anders brief; no meritorious appellate issues identified. Appeal dismissed: guilty-plea appeals are barred except in narrow exceptions, none of which applied.

Key Cases Cited

  • Anders v. California, 386 U.S. 738 (U.S. 1967) (standards for counsel withdrawing via a no-merit brief)
  • Burgess v. State, 490 S.W.3d 645 (Ark. 2016) (explains limited exceptions allowing appeals from guilty pleas)
  • Johnson v. State, 2010 Ark. 63 (Ark. 2010) (addresses appeals from guilty pleas and related exceptions)
  • King v. State, 2013 Ark. App. 342 (Ark. App. 2013) (discusses post-plea evidentiary/sentencing issues that may be appealable)

Appeal dismissed; counsel’s motion to withdraw granted.

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Case Details

Case Name: Matthews v. State
Court Name: Court of Appeals of Arkansas
Date Published: Jan 18, 2017
Citation: 2017 Ark. App. 25
Docket Number: CR-16-477
Court Abbreviation: Ark. Ct. App.