Fields v. Hobbs

Summary

The Supreme Court of Arkansas affirmed the denial of Michael Fields's habeas corpus petition challenging his 2009 guilty-plea rape convictions entered in Perry County and Conway County. Fields argued that the Perry County Circuit Court lacked territorial jurisdiction because the rape occurred in Conway County, and that the Conway County judgment was invalid on its face under the Double Jeopardy Clause because the Perry County judgment bore a struck-through 'MERGED' notation. The court held that Fields failed to carry his burden: his jurisdictional theory attacked the factual basis for his plea, which lies beyond the face of the judgment and is not cognizable in habeas, and nothing on the face of the Conway County judgment showed a prior merger or a double-jeopardy violation. No separate writings were filed.