Charles E. Goodwin v. Dexter Payne, Director, Arkansas Department of Correction

Summary

The Supreme Court of Arkansas affirmed the denial of Charles E. Goodwin’s pro se petition for a writ of habeas corpus. The court held that Goodwin’s claims of actual innocence, insufficient evidence, due-process violations, and trial error did not establish a cognizable basis for habeas relief because they did not challenge the facial validity of the judgment or the trial court’s jurisdiction. Claims raised below but not reasserted on appeal were deemed abandoned.

Holdings

1. A habeas proceeding is limited to challenges to the facial validity of the commitment order or the trial court's jurisdiction and cannot be used to challenge the sufficiency of the evidence supporting the conviction.
2. A petitioner alleging actual innocence must proceed under Act 1780 of 2001 and demonstrate entitlement to scientific testing to prove actual innocence; an ordinary assertion of innocence does not independently support habeas relief.
3. Assertions of trial error and due-process violations do not implicate the facial validity of the judgment or the trial court's jurisdiction and are not cognizable in habeas proceedings.
4. The circuit court did not clearly err in denying Goodwin's petition for failure to demonstrate probable cause for issuance of the writ.

Questions Presented

1. Whether Goodwin's allegation that insufficient evidence supported his conviction stated a cognizable claim for habeas relief.
2. Whether Goodwin's actual-innocence allegation entitled him to habeas relief outside the statutory procedure for scientific testing under Act 1780 of 2001.
3. Whether Goodwin's conclusory due-process allegations and alleged trial errors implicated the facial validity of the judgment or the circuit court's jurisdiction.

Disposition

affirmed