Rangel v. State
2017 Ark. 197
| Ark. | 2017Background
- In August 2014, Rumaldo Rangel pled guilty pursuant to a negotiated plea to possession with intent to deliver methamphetamine and received a two-year term plus a three-year suspended imposition of sentence (SIS).
- At the plea, Rangel was not a naturalized U.S. citizen and later claimed he was not warned about immigration consequences.
- In November 2015 Rangel filed a petition for writ of habeas corpus asserting his counsel failed to provide Padilla v. Kentucky immigration/deportation warnings, entitling him to relief.
- The circuit court denied the habeas petition on June 14, 2016, finding it lacked jurisdiction because Rangel was not in custody in its territorial jurisdiction (he had been deported and was in Mexico).
- The State argued habeas relief was unavailable because Rangel was not in custody; the court and parties treated the claim as moot given his deportation and the SIS status.
- Rangel appealed; the Arkansas Supreme Court affirmed, holding the circuit court lacked jurisdiction to grant habeas relief where the petitioner was not in custody within the court’s jurisdiction.
Issues
| Issue | Rangel's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Rangel is entitled to habeas relief for counsel’s alleged failure to give Padilla warnings about immigration consequences | Rangel: Plea was invalid without Padilla warnings; he remains aggrieved by the SIS and should get relief | State: Habeas unavailable because Rangel is not in custody in the court’s jurisdiction (deported; SIS is not physical custody) | Court: Denied — no jurisdiction to grant habeas because petitioner not in custody in territorial jurisdiction; affirming denial |
Key Cases Cited
- Padilla v. Kentucky, 559 U.S. 356 (Padilla holds counsel must advise noncitizen clients about immigration consequences of guilty pleas)
- Hobbs v. Gordon, 434 S.W.3d 364 (Ark. 2014) (standard of review for habeas-corpus decisions)
- Mackey v. Lockhart, 819 S.W.2d 702 (Ark. 1991) (writ issues only when commitment invalid on its face or court lacked jurisdiction)
- Wallace v. Willock, 781 S.W.2d 484 (Ark. 1989) (same principle regarding habeas relief limits)
- Pardue v. State, 999 S.W.2d 198 (Ark. 1999) (circuit court lacks jurisdiction to release prisoner not in its territorial custody)
- Neely v. McCastlain, 306 S.W.3d 424 (Ark. 2009) (same jurisdictional limitation for habeas relief)
- Reeves v. State, 5 S.W.3d 41 (Ark. 1999) (probation and SIS do not constitute custody for habeas purposes)