Meek v. State, 2013 Ark. 314

Meek pled guilty to meth with intent to deliver, hydrocodone possession, and drug paraphernalia, and was sentenced as a habitual offender to 240 months plus 120 months suspended.
Meek filed a pro se Rule 37.1 petition and a motion for transcript at public expense, which the circuit court denied without a hearing.
He timely appealed the denial, but did not tender the record to the supreme court within 90 days; he filed a belated-appeal request in this court.
The court treated the appeal as a rule-on-clerk motion and ultimately dismissed the appeal as moot because the motion would not succeed.
The petition’s grounds were analyzed under Rule 37.1; most claims were deemed not cognizable or insufficiently supported.
The court upheld denial of a transcript at public expense, noting indigence alone does not qualify for free copying absent a compelling need.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Rule 37.1 claims cognizable when a guilty plea is entered?	Meek contends grounds include ineffective assistance and other postconviction claims.	Prosecution-related and speedy-trial claims are not cognizable post-plea; only certain plea-related claims are.	Most grounds not cognizable; petition denied on cognizability.
Whether prosecutorial misconduct and speedy-trial claims are cognizable in Rule 37.1 post-plea proceedings.	Meek asserts prosecutorial misconduct and speedy-trial denial harmed his defense.	Such claims are trial errors, not cognizable in Rule 37.1 appeals.	Not cognizable; must be raised at trial/appeal.
Whether counsel's effectiveness claims meet Strickland prejudice requirements in Rule 37.1.	Meek alleges ineffective assistance and disclosure of confidential info damaged defense.	No sufficient factual support showing prejudice; claims conclusory.	No prejudice shown; not proven under Strickland.
Whether the circuit court erred in denying production of the transcript at public expense.	Transcript is necessary to prove alleged counsel and prosecutorial issues.	Indigency alone does not guarantee transcript; must show compelling need.	No error; no compelling need shown and claims not transformative.

Denson v. State, 2013 Ark. 209 (Ark. 2013) (appeal from Rule 37.1 denial not allowed if no merit)
Thacker v. State, 2012 Ark. 205 (Ark. 2012) (plea-based Rule 37.1 claims limited to plea validity and counsel)
Scott v. State, 2012 Ark. 199 (Ark. 2012) (prosecutorial misconduct not cognizable in Rule 37.1)
Sandoval-Vega v. State, 2011 Ark. 393 (Ark. 2011) (trial-error claims not cognizable on Rule 37.1 review)
Watson v. State, 2012 Ark. 27 (Ark. 2012) (trial-error claims must be raised at trial and on appeal)
Banks v. State, 2013 Ark. 147 (Ark. 2013) (standard for reviewing Rule 37.1 denials; deferential review)
Daniels v. State, 2013 Ark. 208 (Ark. 2013) (summary disposition when allegations lack merit)
Hickey v. State, 2013 Ark. 237 (Ark. 2013) (clear-error standard for postconviction findings)
Koontz v. State, 2013 Ark. 181 (Ark. 2013) (transcript production and indigency considerations)
Spring v. State, 2012 Ark. 87 (Ark. 2012) (Strickland two-prong test and prejudice requirement)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes standard for ineffective assistance claims)
Thompson v. State, 2013 Ark. 179 (Ark. 2013) (prejudice must be shown with specific facts in Rule 37.1)
Pruitt v. State, 2012 Ark. 199 (Ark. 2012) (practice guidelines for cognizable Rule 37.1 claims)