Arkansas Supreme Court affirms denial of Stanley Hunt’s habeas petition

The Supreme Court of Arkansas on Sept. 19, 2024 affirmed a Lincoln County Circuit Court’s denial and dismissal of Stanley Hunt’s petition for a writ of habeas corpus, concluding the petition did not demonstrate that the judgment or commitment order was invalid on its face or that the trial court lacked jurisdiction.

The opinion, written by Associate Justice Courtney Rae Hudson, explains why Hunt’s three main arguments were insufficient for habeas relief. "A writ of habeas corpus is proper when a judgment and commitment order is invalid on its face or when a trial court lacks jurisdiction over the cause," Hudson wrote. The court found Hunt’s challenges instead raised evidentiary and trial‑error issues that are not cognizable in a habeas proceeding.

Hunt was convicted by a Faulkner County jury of three counts of rape involving his fourteen‑year‑old niece, N.H., and received an aggregate sentence of 480 months. He argued the sentencing order was facially invalid because: (1) the sentencing sheet listed the victim’s age as 15 in count one; (2) count two omitted victim age information; and (3) the alleged victim changed her birth year and the trial court misquoted the statutory age language to the jury. The Supreme Court reiterated that habeas review is limited to facial defects in the judgment or lack of jurisdiction and does not permit re‑litigation of evidentiary sufficiency or credibility determinations made at trial.

The court observed that the judgment expressly identified the offense as rape under Arkansas Code Annotated section 5‑14‑103 and held that resolving the precise statutory subsection or the victim’s exact age would require delving beyond the face of the commitment order. The opinion also noted that a clerical notation of the victim’s age can be corrected by the sentencing court nunc pro tunc and that clerical errors alone do not render a judgment unenforceable. "Clerical errors do not prevent the enforcement of the judgment, and the sentencing court may enter an order nunc pro tunc at any time to correct clerical errors in the judgment," the opinion stated.

The court cited statutory provisions governing habeas corpus proceedings, including Arkansas Code Annotated sections 16‑112‑101 to ‑123, and multiple precedents limiting habeas review to jurisdictional and facial‑validity claims. The opinion references prior appellate decisions addressing similar challenges and reiterates that claims of trial error, disputed jury instructions, and questions about the sufficiency of the evidence should be raised at trial or on direct appeal rather than in habeas proceedings.

The Supreme Court’s judgment affirmed the denial of Hunt’s petition. Special Justice Milton Fine joined the opinion; Justice Hiland did not participate. Stanley Hunt appeared pro se; the Attorney General’s Office was represented by Tim Griffin, Attorney General, through A. Evangeline Bacon, Assistant Attorney General.

Background and procedural notes: Hunt’s conviction and sentence were previously affirmed on direct appeal in Hunt v. State, 2015 Ark. App. 53, 454 S.W.3d 771. The habeas opinion reiterates that an illegal sentence for habeas purposes must exceed statutory maxima, which Hunt did not allege.