Watson v. State
2014 Ark. 147
Ark.2014Background
- Watson was convicted in 2004 of aggravated robbery and theft of property and sentenced to 264 months’ imprisonment in Pulaski County.
- Watson filed a pro se habeas corpus petition in 2013 challenging the judgment-and-commitment order as void for lack of due process and trial court jurisdiction.
- Trial court denied the petition before appellate review.
- The petition alleged the court failed to apply the standard due-process analysis to determine the judgment’s cause.
- Watson later amended his appellate argument to include a claim that evidence at trial was improperly admitted.
- The Arkansas Supreme Court affirmed, holding the habeas corpus petition failed to show facial invalidity or lack of jurisdiction, so relief was not warranted.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether habeas relief is proper for alleged trial error. | Watson; due-process claim shows denial of rights. | State; habeas requires facial invalidity or lack of jurisdiction, not trial errors. | No; habeas relief denied for lack of facial invalidity or jurisdiction. |
Key Cases Cited
- Glaze v. Hobbs, 2013 Ark. 458 (Ark. 2013) (habeas corpus only for facial invalidity or lack of jurisdiction)
- Abernathy v. Norris, 2011 Ark. 335 (Ark. 2011) (per curiam; habeas focus on facial validity or jurisdiction)
- Davis v. Reed, 316 Ark. 575, 873 S.W.2d 524 (Ark. 1994) (habeas corpus burden to show invalidity or lack of jurisdiction)