Summary
The Arkansas Supreme Court affirmed the denial of Michael Fields's petition for a writ of habeas corpus. The court held that Fields did not establish probable cause to show that the Perry County Circuit Court lacked territorial jurisdiction over his rape conviction, and that the Conway County judgment was not facially invalid or barred by double jeopardy. The court also declined to speculate about the meaning of a “MERGED” notation in the Perry County judgment.
Topics
Practice areas
Questions Presented
- Whether Fields established probable cause that the Perry County Circuit Court lacked territorial jurisdiction because the rape to which he pleaded guilty occurred in Conway County.
- Whether the Conway County judgment was facially invalid and barred by double jeopardy because the Perry County judgment contained a "MERGED" notation.
Holdings
- Fields failed to demonstrate probable cause that the Perry County Circuit Court lacked territorial jurisdiction because the face of the judgment did not establish where, when, or against whom the offense occurred, and his challenge depended on facts concerning the factual basis of his guilty plea that went beyond the face of the judgment.
- The Conway County judgment was not facially invalid and did not establish a double-jeopardy violation because nothing on its face showed that the relevant count had been merged into the Perry County judgment or that Fields had been sentenced twice for the same offense.
Key quotations
“A writ of habeas corpus is proper only when a judgment of conviction is invalid on its face or when a circuit court lacked jurisdiction over the cause.” (2013 Ark. 416 at 4)
“A guilty plea may not be accepted without first establishing that there is a factual basis for the plea.” (2013 Ark. 416 at 5)
Factual background
Fields was charged with rape offenses in both Conway County and Perry County. He pleaded guilty to one rape count in Perry County and later pleaded guilty to one additional rape count in Conway County; each court imposed a ten-year sentence, to run concurrently. The Perry County judgment contained an unexplained strikethrough notation stating "MERGED," while neither judgment identified the victim or clearly specified the count to which Fields pleaded guilty.
Procedural history
Fields pleaded guilty to rape charges in the Perry County and Conway County Circuit Courts in 2009 and received concurrent ten-year sentences. While incarcerated in Hot Spring County, he filed a habeas petition alleging that the Perry County court lacked territorial jurisdiction and that the Conway County judgment was facially invalid and violated double jeopardy. The Hot Spring County Circuit Court denied relief, and the Supreme Court of Arkansas affirmed.