Strong v. Hobbs, 2013 Ark. 376

Richard Strong, serving consecutive life sentences after rape convictions affirmed on direct appeal (Strong v. State), filed a pro se state habeas petition in Lee County challenging his conviction on multiple grounds.
Strong alleged due-process violations, ineffective assistance of counsel, prosecutorial misconduct, actual innocence, and trial-court errors; he sought an evidentiary hearing and written findings.
The Lee County Circuit Court dismissed the petition without a hearing, concluding Strong failed to show facial invalidity of the judgment or lack of jurisdiction.
Strong appealed, arguing the dismissal, lack of hearing, and absence of written findings were erroneous; he also repeated claims previously raised in postconviction filings.
The Arkansas Supreme Court applied the statutory habeas standard requiring a petitioner to show facial invalidity or lack of jurisdiction (or, for actual-innocence claims under Act 1780, new scientific evidence) and affirmed the dismissal.

Issue	Plaintiff's Argument (Strong)	Defendant's Argument (Hobbs)	Held
Whether habeas relief was available because conviction was invalid	Conviction violated due process; trial errors, ineffective assistance, prosecutorial misconduct, and actual innocence warrant habeas relief	Habeas is available only if judgment is facially invalid or trial court lacked jurisdiction; Strong did not plead or prove either	Denied — Strong failed to show facial invalidity or lack of jurisdiction
Whether the court erred by not holding an evidentiary hearing	He was prejudiced by absence of a hearing on his petition	No hearing required unless probable cause for the writ is shown by affidavit or other evidence	Denied — no hearing required because probable cause not shown
Whether the circuit court erred by failing to issue written findings	Court’s brief order was insufficient; detailed written findings were needed	Statutory habeas scheme (outside Act 1780) does not require written findings	Denied — no statutory requirement for written findings
Whether claims (ineffective assistance, trial error, actual innocence) are cognizable in habeas	These claims justify habeas relief and an evidentiary hearing	Such claims are trial errors and not cognizable in habeas; actual-innocence claims require Act 1780’s new-scientific-evidence showing	Denied — trial-error claims not cognizable; no Act 1780 showing of new scientific evidence

Strong v. State, 372 Ark. 404, 277 S.W.3d 159 (Ark. 2008) (direct-appeal affirmance of Strong’s convictions)
Young v. Norris, 365 Ark. 219, 226 S.W.3d 797 (Ark. 2006) (burden on habeas petitioner to show court lacked jurisdiction or judgment invalid on its face)
Mackey v. Lockhart, 307 Ark. 321, 819 S.W.2d 702 (Ark. 1991) (no absolute right to habeas hearing regardless of petition content)
McConaughy v. Lockhart, 310 Ark. 686, 840 S.W.2d 166 (Ark. 1992) (ineffective-assistance claims not cognizable in habeas)