Rice v. State, 2014 Ark. 230

Rice was convicted in 2010 for possession of cocaine and resisting arrest, and sentenced as a habitual offender to 360 months’ imprisonment.
The Arkansas Court of Appeals affirmed the conviction and sentence.
In 2012 Rice, pro se, filed a Rule 37.1 postconviction petition alleging ineffective assistance, prosecutorial misconduct, and due-process violations.
The circuit court denied the petition without a hearing; Rice appealed.
Rice sought to supplement the record with additional documents; the court granted some supplementation previously but declined to include new items.
The Supreme Court granted review to consider postconviction record supplementation requests and the petition’s merits; ultimately dismissed the appeal as no reversible relief appeared.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the record should be supplemented.	Rice seeks inclusion of documents not referenced by the circuit court.	Record supplementation not warranted absent circuit-court-referenced materials.	Motions to supplement or settle the record denied.
Whether the appeal should be dismissed as lacking merit under Rule 37.1.	Rice contends postconviction relief should be granted based on claims of ineffective assistance and misconduct.	Record shows no reversible error; petition fails to show entitlement to relief.	Appeal dismissed; postconviction relief denied.
Whether trial counsel was ineffective under Strickland.	Counsel conspired with the prosecutor and failed to raise issues.	Arguments are conclusory and lack factual substantiation; no prejudice shown.	No error; Strickland claims rejected.
Whether prosecutorial misconduct or due-process claims are cognizable on Rule 37.1 review.	Prosecutor fabricated charges and withheld witness information; lack of probable cause.	Claims are conclusory, refuted by record, and are trial-error claims not cognizable here.	Claims dismissed as trial errors not proper Rule 37.1 grounds.

Holliday v. State, 2013 Ark. 47 (Ark. 2013) (postconviction review standards; deference to circuit court findings)
Bates v. State, 2012 Ark. 394 (Ark. 2012) (per curiam; limitations of Rule 37.1 relief)
Martin v. State, 2012 Ark. 312 (Ark. 2012) (per curiam; default standards for postconviction relief)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong standard for ineffective assistance of counsel)
Hickey v. State, 2013 Ark. 237 (Ark. 2013) (totality of the evidence; standard for ineffective assistance)
Springs v. State, 2012 Ark. 87 (Ark. 2012) (Strickland standard; deference to counsel)
Wedgeworth v. State, 2013 Ark. 119 (Ark. 2013) (conclusory claims insufficient to sustain postconviction relief)
Crain v. State, 2012 Ark. 412 (Ark. 2012) (per curiam; lack of factual substantiation in claims)
Hale v. State, 2011 Ark. 476 (Ark. 2011) (trial-errors must be raised at trial/direct appeal)
Viveros v. State, 2009 Ark. 548 (Ark. 2009) (constitutional claims not cognizable on postconviction review)
Eason v. State, 2011 Ark. 352 (Ark. 2011) (evidentiary-hearing requirements in Rule 37.3(a))
Hayes v. State, 2011 Ark. 327 (Ark. 2011) (Rule 37.3(a) considerations; per curiam)
Reed v. State, 2011 Ark. 115 (Ark. 2011) (per curiam; evidentiary standards in postconviction)
Pankau v. State, 2013 Ark. 162 (Ark. 2013) (clearly erroneous standard; postconviction review)
Banks v. State, 2013 Ark. 147 (Ark. 2013) (deference to circuit court findings in postconviction)