Ricky Lee Scott v. Dexter Payne, Director, Arkansas Department of Correction

Citation: 2022 Ark. 178

Court: Supreme Court of Arkansas; October 6, 2022; Arkansas; State Supreme Court

Original Court Document: View Document

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Ricky Lee Scott appealed the Lincoln County Circuit Court's dismissal of his motion for a new trial and petition for habeas corpus. He raised three main arguments: (1) the circuit court lacked jurisdiction to impose his first-degree murder conviction because the jury was not properly instructed on the elements of first-degree murder; (2) his life sentence was illegal for the same reason; and (3) his conviction and sentence violated his Fourteenth Amendment due process rights, as well as Fifth Amendment protections against double jeopardy, due to the lack of proper jury instructions. The Supreme Court of Arkansas affirmed the lower court's decision, noting that Scott's claims regarding jury instructions were trial errors that should have been raised earlier, either at trial, on direct appeal, or in a timely Rule 37 postconviction petition. The circuit court determined that Scott failed to present precedents supporting his claims within the context of habeas corpus, concluding that the issues did not affect the facial validity of the judgment or the court's jurisdiction.

On September 9, 2021, Scott filed a motion for a new trial under Rule 59 of the Arkansas Rules of Civil Procedure. In response to the circuit court's determination that Scott failed to cite relevant legal precedent for his habeas relief claim, Scott acknowledged the absence of Arkansas case law but contended that this should not hinder a merits review. On September 23, 2021, the circuit court dismissed his habeas corpus petition, stating that Scott's primary argument revolved around purportedly improper jury instructions. The court noted that these claims had been previously rejected by the Arkansas Supreme Court. It clarified that a writ of habeas corpus is warranted only when a conviction is facially invalid or when the trial court lacked jurisdiction; claims of jury instruction errors are considered trial errors and do not affect the judgment's validity or jurisdiction. Scott argued that his attached documents demonstrated probable cause for his illegal detention, but the court emphasized that the substance of the documents, not their inclusion, determines this. The court found that Scott's claims do not qualify for habeas relief, reiterating that trial errors do not establish probable cause. Scott's attempt to broaden the scope of habeas relief was dismissed, as he could not provide supporting precedent. He appealed the dismissal order and the denial of his motion for a new trial on October 18, 2021. The standard of review for a circuit court's decision on a habeas petition is whether it is clearly erroneous, and a writ is appropriate only if the judgment is facially invalid or the court lacked jurisdiction. Additionally, a petitioner must either allege actual innocence or demonstrate the invalidity of the judgment or lack of jurisdiction, supported by evidence of probable cause for illegal detention.

Proceedings for a writ of habeas corpus are limited to reviewing the commitment order's face, without extensive trial record examination. A petitioner must demonstrate that the circuit court lacked jurisdiction or that the commitment order was invalid on its face to justify the issuance of a writ. In Scott's appeal regarding his first-degree murder conviction, he claims the circuit court lacked jurisdiction because it did not instruct the jury on the elements of first-degree murder. Although Scott does not dispute the facial validity of the judgment, he admits the circuit court had both personal and subject-matter jurisdiction over the case. His argument, however, suggests that the court's failure to instruct the jury constitutes a jurisdictional error, which he argues is a novel issue. The circuit court characterized this failure as a trial error, which cannot be addressed in habeas proceedings. Scott contends this mischaracterization is erroneous, maintaining that the lack of jury instruction rendered the conviction beyond the court's authority. The State counters that Scott's claims essentially relate to trial error. The court affirms that habeas corpus relief is narrowly defined and does not extend to Scott's arguments. Additionally, Scott asserts that the conviction lacks sufficient evidence for each required element, arguing that under Arkansas law, a valid conviction must be supported by substantial evidence proving each element beyond a reasonable doubt, and he claims the circuit court failed to find sufficient evidence for his conviction.

Scott's claim regarding jurisdiction is ultimately about the sufficiency of the evidence, which cannot be challenged in habeas proceedings, as established in Clark v. Kelley and Jones v. State. Habeas corpus is limited to specific issues, such as the facial validity of the commitment order or the trial court's jurisdiction, neither of which Scott invokes. He references Bennett v. State, where the circuit court failed to properly instruct the jury, but this case is not applicable because it involved a direct appeal and a specific request for jury instructions, which Scott did not make. 

Scott also cites Arkansas Code Annotated section 16-112-118(b)(1), which outlines circumstances under which a prisoner may be discharged from custody. He argues that his conviction lacks a jury finding of guilt beyond a reasonable doubt, making the process void under subdivision (b)(1)(C). However, this claim, tied to trial errors, is not valid for habeas review. Furthermore, the court does not interpret subdivision (b)(1)(C) as applicable in Scott's case. Regarding subdivision (b)(1)(D), Scott contends that the jury's lack of proper instruction on first-degree murder invalidates the order, but this focus on the order's validity does not support a valid habeas claim.

Unauthorized process concerning an order is outlined in subdivision (b)(1)(F). Scott contends that his conviction is unauthorized by law because the jury was not instructed on all elements of first-degree murder. However, it is acknowledged that the order was valid, and the circuit court had appropriate jurisdiction. Thus, the order issued was lawful. The court emphasizes that Scott’s argument, framed as a jurisdictional issue, is fundamentally a trial error, which is not relevant in habeas proceedings as it does not challenge the judgment's facial validity or the trial court's jurisdiction. Consequently, the circuit court acted correctly in dismissing Scott’s habeas petition.

Regarding his sentence, Scott argues that his life sentence is illegal due to the lack of jury instructions on first-degree murder elements, mirroring his earlier trial-error claim. Since this does not present a valid habeas claim, it is similarly dismissed.

In his final argument, Scott claims that his conviction and life sentence violate his due-process rights under the Fourteenth Amendment and invoke double jeopardy under the Fifth Amendment, alleging that he was improperly convicted when the jury was only instructed on second-degree murder. The State counters that Scott's claims are premature as he has not shown illegal detention or the threat of double prosecution. The court concurs, stating that without evidence of a lack of jurisdiction or an invalid commitment order, there is no basis for habeas relief. The circuit court's dismissal of Scott's claims is affirmed.