John Irving Rawls v. Michelle Gray, Warden

Summary

The Supreme Court of Arkansas affirmed the dismissal of John Irving Rawls’s pro se petition for a writ of habeas corpus. The court held that Rawls’s conviction for first-degree discharge of a firearm from a vehicle was properly classified as a Class Y felony and that his twenty-five-year sentence was within the authorized statutory range. The court also concluded that habeas corpus was not the proper vehicle for challenging whether Rawls knowingly entered his guilty plea.

Holdings

1. Rawls's sentence was legal because the General Assembly classified first-degree discharge of a firearm from a vehicle as a Class Y felony in 1993, and his 300-month sentence was within the statutory maximum of forty years or life for a Class Y felony.
2. A habeas corpus petition is not the proper means to contest whether Rawls knowingly pleaded guilty to a Class Y felony.
3. The circuit court did not clearly err in dismissing Rawls's petition because he failed to demonstrate that the judgment was facially invalid or that the trial court lacked jurisdiction.

Questions Presented

1. Whether Rawls's conviction and sentence for discharging a firearm from a vehicle were facially invalid or unauthorized because the offense was classified as a Class Y felony rather than a Class B felony.
2. Whether Rawls could use a habeas corpus petition to challenge whether he knowingly pleaded guilty to a Class Y felony.

Disposition

affirmed