Wheeler v. State, 2015 Ark. 233

Wheeler was convicted in 2013 of first-degree battery and sentenced to 360 months in prison.
Wheeler’s conviction was affirmed on direct appeal by the Arkansas Court of Appeals.
Wheeler filed a pro se Rule 37.1 postconviction petition alleging ineffective assistance and other trial errors; the petition was denied.
He filed multiple motions for extensions of time, transcript access, and counsel, and submitted a brief with a supplement.
The Supreme Court dismissed the appeal as moot because the petition lacked a meritorious claim for relief under Rule 37.1; the review follows Strickland and related standards for ineffective assistance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wheeler’s Rule 37.1 petition stated a meritorious claim.	Wheeler contends ineffective assistance and trial errors.	State argues petition failed to present a meritorious claim.	Petition lacks meritorious claim; appeal dismissed.
Whether trial counsel’s alleged deficiencies warranted relief under Strickland.	Wheeler alleges ineffective assistance due to failure to investigate and other omissions.	State argues no prejudice shown and claims lack specific facts.	No prejudice shown; Strickland two-prong test not satisfied.
Whether failure to object to certain evidence or statements prejudiced Wheeler.	Counsel should have objected to stick evidence and prosecutor’s statements.	Objections either lacked merit or statements were not prejudicial.	Objections lack meritorious basis; no prejudice established.
Whether seating of a juror with alleged bias affected outcome.	Juror biased due to family ties to railroad workers.	Juror could set aside experiences and decide based on evidence.	Insufficient bias to deny a fair trial.
Whether sentencing notation affected parole eligibility and trial strategy.	Noted parole status could have been challenged.	Noting parole status was proper; relief not warranted.	Not prejudicial; remedy unaffected.

Winters v. State, 441 S.W.3d 22 (2014 Ark.) (dismissal when no meritorious postconviction claim)
State v. Rainer, 440 S.W.3d 315 (2014 Ark.) (Rule 37.1 relief not available for trial errors available at trial or on appeal)
Stewart v. State, 443 S.W.3d 538 (2014 Ark.) (trial errors do not qualify as Rule 37.1 relief)
Sales v. State, 441 S.W.3d 883 (2014 Ark.) (Strickland prejudice required to prevail)
Mister v. State, 448 S.W.3d 200 (2014 Ark.) (reasonable probability required to show prejudice)
Young v. State, 2015 Ark. 65 (Ark. 2015) (failure to investigate must show material, outcome-altering information)