Stacy v. Payne

United States District Court for the Eastern District of Arkansas, Central Division · August 27, 2025 · No. 4:25-cv-00298-JM-ERE

Summary

This document is a United States District Court Magistrate Judge’s Recommended Disposition regarding a federal habeas corpus petition filed by an Arkansas state prisoner. The petitioner challenges his capital murder conviction, arguing that overlapping state statutes violated due process and equal protection rights. Applying the deferential standard under the Antiterrorism and Effective Death Penalty Act, the magistrate judge concludes that the Arkansas Supreme Court’s rejection of the claim was not unreasonable and recommends dismissing the petition with prejudice and denying a certificate of appealability.

Court
United States District Court for the Eastern District of Arkansas, Central Division
Writing for the Court
Magistrate Judge
Jurisdiction
United States District Court for the Eastern District of Arkansas
Decision date
August 27, 2025
Docket number
4:25-cv-00298-JM-ERE
Procedural posture
Petition for writ of habeas corpus under 28 U.S.C. § 2254
Standard of review
Deferential review under 28 U.S.C. § 2254(d)
Precedential value
nonprecedential
Parties
Cordale Stacy v. Dexter Payne, Director, Arkansas Division of Correction
Disposition
dismissed

Topics

federal habeas corpuspost-conviction reliefcriminal procedure

Practice areas

criminal procedurepost-conviction relief

Questions Presented

  1. Whether Stacy's habeas petition is barred because the claim was adjudicated on the merits in state court and is entitled to deference under 28 U.S.C. § 2254(d).

Holdings

  1. The petition is dismissed with prejudice because the single claim was previously adjudicated on the merits by the Arkansas Supreme Court and is entitled to deference under § 2254(d).

Key quotations

“So long as overlapping criminal provisions clearly define the conduct prohibited and the punishment authorized, the notice requirements of the Due Process Clause are satisfied. United States v. Batchelder, 442 U.S. 114, 123 (1979).”

Factual background

Cordale Stacy was convicted of capital murder of a mother and her two minor children in St. Francis County, Arkansas, receiving three life sentences without parole and a fifteen‑year firearm enhancement. He argued that the statutory overlap between the capital murder charges and lesser‑included offenses violated his due‑process rights.

Procedural history

Stacy was convicted of capital murder in Arkansas state court, appealed directly, and the Arkansas Supreme Court affirmed his convictions and rejected his statutory overlap argument. He subsequently filed a federal habeas petition in the Eastern District of Arkansas.

Court Document

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