Taylor v. State, 2017 Ark. 279

Appellant Rickey Tyrone Taylor filed a pro se petition for writ of habeas corpus seeking to withdraw his guilty plea, alleging the State breached the negotiated plea agreement and that he never agreed to serve 70% of his sentence before parole eligibility.
Taylor conceded the original judgment and sentence were valid but argued the State’s alleged breach rendered the judgment void.
The Lee County Circuit Court denied the habeas petition; Taylor appealed and filed multiple pro se motions (extensions, appointment of counsel, duplication of motion).
The appellate court reviewed whether Taylor’s petition invoked habeas relief by alleging a facially invalid judgment or lack of subject-matter jurisdiction.
The court determined Taylor’s claims sounded in Rule 37 postconviction relief or parole eligibility issues rather than habeas jurisdictional defects.
Because Taylor failed to state a ground for habeas relief and could not prevail on appeal, the court dismissed the appeal and found the ancillary motions moot.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether habeas corpus is proper to withdraw a guilty plea based on alleged plea-bargain breach	Taylor: State breached plea agreement and thus judgment is void; plea withdrawal warranted	State: Judgment is valid; alleged breaches/plea voluntariness are Rule 37 or non-habeas matters	Denied — habeas not proper; claim must be pursued under Rule 37 or other remedies
Whether habeas may be used for involuntary plea or improper plea procedures	Taylor: Plea was involuntary / procedures improper, so habeas relief appropriate	State: Such claims do not render sentence void and belong in postconviction proceedings	Denied — involuntary-plea claims are not grounds for habeas
Whether habeas addresses parole-eligibility disputes	Taylor: Challenged 70% parole-eligibility term attached to plea	State: Parole eligibility is executive domain, not subject to habeas	Denied — parole eligibility is not cognizable in habeas
Whether appellate dismissal is appropriate when appellant cannot prevail	Taylor: Appealed denial of habeas	State: Record shows no viable habeas ground	Dismissed — appeal dismissed as appellant could not prevail

Hobbs v. Gordon, 434 S.W.3d 364 (Ark. 2014) (standard of review for habeas denial; clearly erroneous test)
Green v. State, 502 S.W.3d 524 (Ark. 2016) (appeal from postconviction denied where appellant could not prevail)
Philyaw v. Kelley, 477 S.W.3d 503 (Ark. 2015) (habeas proper only for facially invalid judgments or lack of jurisdiction)
Baker v. Norris, 255 S.W.3d 466 (Ark. 2007) (circuit court subject-matter jurisdiction over criminal statutes)
Webb v. State, 223 S.W.3d 796 (Ark. 2006) (motions to withdraw guilty plea must proceed under Rule 37)
Noble v. Norris, 243 S.W.3d 260 (Ark. 2006) (habeas is not a substitute for timely postconviction relief)
Blevins v. Norris, 722 S.W.2d 573 (Ark. 1987) (parole eligibility is executive branch matter, not for habeas)