2013 Ark. 309
Ark.2013Background
- Parker pled guilty to first-degree murder and kidnapping in Greene County and was sentenced to life imprisonment.
- In September 2010, Parker filed a habeas corpus petition in Lincoln County, arguing due-process violations at his guilty-plea hearing related to Arkansas Rules of Criminal Procedure Rules 24.4–24.6.
- The trial court dismissed the habeas petition, and Parker appealed.
- The Arkansas Supreme Court reviews habeas petitions to determine if the judgment is facially invalid or if the trial court lacked jurisdiction.
- The court explains habeas relief does not permit retrying the case or serving as a substitute for direct appeal.
- The court ultimately affirms the denial, holding Parker failed to show facial invalidity or lack of jurisdiction, and also rejected his isolation-treatment claim as non-cognizable in habeas relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas relief was proper where plea-void claims do not facially invalidate the judgment. | Parker alleging due-process defects at plea. | Hobbs argues petition lacks facial invalidity or lack of jurisdiction. | Not cognizable; no facial invalidity or lack of jurisdiction. |
| Whether isolation during pretrial detention supports habeas relief. | Isolation affected Parker's decision to plead guilty. | Claim does not challenge facial validity or jurisdiction. | No basis for habeas relief; petition properly denied. |
Key Cases Cited
- Girley v. Hobbs, 2012 Ark. 447 (Ark. 2012) (habeas relief requires facial invalidity or lack of jurisdiction)
- Abernathy v. Norris, 2011 Ark. 335 (Ark. 2011) (per curiam habeas standard; facial validity/lack of jurisdiction)
- Young v. Norris, 365 Ark. 219 (Ark. 2006) (probable cause requirement in habeas; not direct appeal)
- Murry v. Hobbs, 2013 Ark. 64 (Ark. 2013) (per curiam; pleading facial invalidity or lack of jurisdiction)
- Culbertson v. State, 2012 Ark. 112 (Ark. 2012) (due-process claims not cognizable in habeas when not facially invalid)
- Skinner v. Hobbs, 2011 Ark. 383 (Ark. 2011) (habeas limits on factual inquiries about plea)
- Friend v. Norris, 364 Ark. 315 (Ark. 2005) (habeas proceeding not a direct appeal or postconviction relief)
- McHaney v. Hobbs, 2012 Ark. 361 (Ark. 2012) (due-process allegations not cognizable in habeas)