Stephenson v. Kelley
544 S.W.3d 44
| Ark. | 2018Background
- Deandra L. Stephenson, convicted in 2007 of two counts of capital murder and one count of committing a terroristic act, received life without parole and an enhanced 480-month term; this Court previously affirmed his convictions.
- In 2017 Stephenson filed a pro se habeas petition in the circuit court alleging trial error, insufficiency of evidence, and actual innocence; he did not claim sentences were outside statutory range or that the trial court lacked jurisdiction.
- Stephenson argued the habeas court should look beyond the face of the judgment (i.e., consider trial errors and evidence sufficiency) rather than being limited to facial defects or jurisdictional defects.
- The circuit court dismissed the petition, concluding Stephenson failed to show the judgment was facially invalid or that the trial court lacked jurisdiction, as required by Arkansas statute for habeas petitions not invoking Act 1780.
- The Arkansas Supreme Court affirmed, holding habeas relief is unavailable for claims of trial error or sufficiency-of-evidence/actual-innocence claims unless statutory procedures (e.g., Act 1780) are invoked; dissent argued the court should follow the statute’s plain language and allow broader inquiry.
Issues
| Issue | Plaintiff's Argument (Stephenson) | Defendant's Argument (State/Court) | Held |
|---|---|---|---|
| Scope of habeas review — whether court may look beyond face of judgment | Habeas court should consider trial errors and evidence sufficiency; not limited to facial validity | Habeas statute (as interpreted) limits review to facial invalidity or lack of jurisdiction unless Act 1780 applies | Held: Habeas proceedings are limited to facial invalidity or lack of jurisdiction; broader trial-error review is not available on habeas |
| Actual innocence claim | Stephenson: he is actually innocent and thus entitled to habeas relief | State/Court: actual-innocence claims challenge sufficiency of evidence and are due-process claims not cognizable in habeas proceedings | Held: Actual-innocence/sufficiency claims are not cognizable in habeas; denial affirmed |
| Trial error/due-process claims (e.g., evidentiary rulings, confrontation, jury instructions) | These errors violated due process and warrant issuance of writ | Trial errors are not grounds for habeas; remedy is direct appeal; habeas will not correct trial irregularities | Held: Trial-error claims are not grounds for habeas and were properly rejected |
| Statutory pleading requirements (affidavit/probable cause; Act 1780) | Stephenson did not invoke Act 1780 but argued statute should be read to permit broader review | Court: Under §16-112-103(a) and precedent, petitioner must show facial invalidity or lack of jurisdiction unless proceeding under Act 1780; petitioner failed to meet statutory standard | Held: Petition dismissed for failure to allege facial invalidity or lack of jurisdiction and to make required showing; affirmation of dismissal |
Key Cases Cited
- Stephenson v. State, 373 Ark. 134, 282 S.W.3d 772 (Ark. 2008) (affirming convictions)
- Birchett v. State, 303 Ark. 220, 795 S.W.2d 53 (1990) (habeas is not a means to retry trial issues)
- Sawyer v. State, 327 Ark. 421, 938 S.W.2d 843 (1997) (Arkansas precedent limiting habeas to facial invalidity or lack of jurisdiction)
- Frank v. Mangum, 237 U.S. 309 (1915) (federal expansion of habeas inquiry beyond record to test truth of detention)
- Ex parte Watkins, 28 U.S. (3 Pet.) 193 (U.S. 1830) (historical common-law rule on habeas)
- State v. Martineau, 149 Ark. 237, 232 S.W. 609 (1921) (Ark. court addressed federal Mangum decision but declined its application to state habeas)