Summary
The Supreme Court of Arkansas reversed and remanded an order granting habeas-corpus relief to James Grubbs, who had received a mandatory sentence of life imprisonment without parole for a capital-murder conviction committed while he was a juvenile. The court held that the circuit court failed to follow the statutory procedures requiring a probable-cause determination and a return before granting habeas relief, relying on its companion decision in Hobbs v. Hodge. The court did not reach the merits of whether Miller v. Alabama applied retroactively to Grubbs's sentence.
Topics
Practice areas
Questions Presented
- Whether Miller v. Alabama applies retroactively on collateral review to invalidate Grubbs's mandatory life-without-parole sentence for a homicide committed while he was a juvenile.
- Whether the circuit court erred by granting habeas-corpus relief without first determining probable cause and requiring the State to file a return under the governing Arkansas habeas statute.
Holdings
- A circuit court may not grant habeas-corpus relief before determining that probable cause exists for issuing the writ and requiring the respondent to file a return addressing the confinement and material facts. Because the circuit court granted relief prematurely, its order must be reversed and the matter remanded for further proceedings.
Key quotations
“It contends that the circuit court prematurely granted the writ and afforded habeas-corpus relief before making a determination of probable cause and without requiring it to file a return to justify the confinement and to enable the court to determine the material facts.” (at 4)
Factual background
Grubbs pleaded guilty to capital murder in 1995 and received a negotiated sentence of life without the possibility of parole. His judgment stated that he was born on May 4, 1977, and that he committed the offense on March 8, 1995, making him under eighteen at the time of the offense. He later sought habeas relief under Miller v. Alabama, alleging that his mandatory juvenile life-without-parole sentence violated the Eighth Amendment. The circuit court granted relief after a hearing at which no evidence was taken and before requiring the State to file a return.
Procedural history
Grubbs pleaded guilty to capital murder in White County Circuit Court in 1995 and received a sentence of life imprisonment without parole. In 2013, while incarcerated in Lee County, he filed a habeas petition asserting that his mandatory life-without-parole sentence violated Miller because he was a juvenile when he committed the offense. The Lee County Circuit Court granted relief without first determining probable cause or requiring the State to file a formal return. The Supreme Court of Arkansas reversed and remanded, adopting its reasoning from the companion case Hobbs v. Hodge.
Remand instructions
The Lee County Circuit Court must conduct further habeas proceedings in compliance with the statutory procedure, including determining whether probable cause exists for issuance of the writ and requiring the State to file a return before resolving the merits.