Thomas Crockett v. Dexter Payne, Director, Arkansas Division of Correction

Summary

The Arkansas Supreme Court affirmed the denial of Thomas Crockett’s second petition for a writ of habeas corpus. The court held that his challenges concerning the charging information, alleged ineffective assistance of counsel, and due process were not cognizable in habeas proceedings because they did not establish facial invalidity of the judgment or a lack of jurisdiction; his motion to file a belated reply brief was moot.

Holdings

1. Claims that the information was defective or that a new information was required after the charge was reduced from capital murder to first-degree murder are claims of trial error and are not cognizable in a habeas proceeding.
2. Ineffective-assistance-of-counsel claims, including claims concerning plea negotiations and counsel's investigation, are not cognizable grounds for a writ of habeas corpus.
3. A court considering a habeas petition is not required to go beyond the face of the judgment to address the petitioner's claims, and the petitioner bears the burden of showing that the face of the judgment is invalid.
4. The circuit court did not clearly err in denying Crockett's habeas petition because he failed to raise a cognizable habeas claim.

Questions Presented

1. Whether alleged defects in the charging document and the reduction of the charge from capital murder to first-degree murder were cognizable grounds for habeas relief.
2. Whether alleged ineffective assistance of counsel during plea proceedings and plea negotiations supported issuance of a writ of habeas corpus.
3. Whether the circuit court violated due process by refusing to consider matters beyond the face of the judgment in denying the habeas petition.
4. Whether the circuit court clearly erred in denying Crockett's second habeas petition.

Disposition

affirmed