Williams v. State
2016 Ark. 16
| Ark. | 2016Background
- Jackie L. Williams was convicted in Pulaski County on three separate rape counts (1995); each count was tried separately and resulted in convictions with habitual-offender enhancements producing two life terms and one 25-year term, to be served consecutively.
- Williams previously appealed each conviction; this court and the court of appeals affirmed the convictions and sentences in earlier proceedings.
- In April 2015 Williams filed a pro se petition under Ark. Code Ann. § 16-90-111 seeking correction of an "illegal sentence," arguing the amended information was unconstitutional and raising double-jeopardy, Brady, and grand-jury-indictment claims.
- The trial court denied relief; Williams appealed the denial of the § 16-90-111 petition to the Arkansas Supreme Court.
- The central legal question was whether the sentences were "illegal on their face" (thus correctable at any time under § 16-90-111) or whether Williams’s claims raised constitutional errors that must be pursued by other remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether sentences were illegal on their face | Williams: sentences illegal because charging instrument/amended information unconstitutional | State: sentences were within statutory range and thus facially legal | Held: Sentences not illegal on face; within statutory range, § 16-90-111 relief not available |
| Double jeopardy / defective information | Williams: amended information encompassed three offenses and led to multiple trials for same offense (double jeopardy) | State: information by prosecutor is permissible; Arkansas allows prosecution by information; prior challenges do not render sentence facially illegal | Held: Double-jeopardy/charging-instrument claim not cognizable under § 16-90-111; claim previously rejected by Ark. law |
| Brady violation (failure to disclose exculpatory evidence) | Williams: State suppressed exculpatory evidence, affecting fairness of convictions | State: Brady and other constitutional claims do not make an otherwise facially valid sentence illegal; such claims belong in trial/appeal or Rule 37.1 proceedings | Held: Brady claim does not render sentence facially illegal and is not cognizable under § 16-90-111 |
| Right to grand-jury indictment | Williams: entitled to indictment by grand jury under Rule 7 and federal/Arkansas law | State: Arkansas Constitution and precedent permit prosecution by information; no federal grand-jury right in state prosecutions | Held: No right to grand-jury indictment in Arkansas state prosecutions; claim insufficient to void sentence under § 16-90-111 |
Key Cases Cited
- Walden v. State, 2014 Ark. 193 (statute allows trial court to correct illegal sentence at any time because facially illegal sentence implicates jurisdiction)
- Halfacre v. State, 2015 Ark. 105 (portion of § 16-90-111 permitting challenges to facially illegal sentences remains effective)
- Bell v. State, 2015 Ark. 370 (sentence illegal on its face when it exceeds statutory maximum)
- Ehler v. State, 2015 Ark. 107 (sentences within statutory range are facially legal and not subject to § 16-90-111)
- Redus v. State, 2013 Ark. 9 (constitutional errors that do not affect facial validity of sentence are not cognizable under § 16-90-111)
- Stanley v. State, 2013 Ark. 483 (constitutional claims should be raised at trial, on direct appeal, or in Rule 37.1 postconviction proceedings)
- Smith v. State, 2012 Ark. 311 (Ark. Const. amendment allows prosecution by information; no state right to grand-jury indictment)
- Taylor v. State, 303 Ark. 586 (1990) (Arkansas precedent refusing to extend a right to grand-jury indictment in state proceedings)
- Hurtado v. California, 110 U.S. 516 (1884) (U.S. Supreme Court: states not required to charge by grand jury)