Derek Blasingame v. State of Arkansas

2025 Ark. App. 259
CourtCourt of Appeals of Arkansas
DecidedApril 23, 2025
StatusPublished
Cited by1 cases

This text of 2025 Ark. App. 259 (Derek Blasingame v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Derek Blasingame v. State of Arkansas, 2025 Ark. App. 259 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 259 ARKANSAS COURT OF APPEALS DIVISION I No. CR-24-265

Opinion Delivered April 23, 2025 DEREK BLASINGAME APPELLANT APPEAL FROM THE SEBASTIAN COUNTY CIRCUIT COURT, FORT V. SMITH DISTRICT [NO. 66FCR-22-331] STATE OF ARKANSAS APPELLEE HONORABLE R. GUNNER DELAY, JUDGE

AFFIRMED

MIKE MURPHY, Judge

Derek Blasingame filed a timely petition in the circuit court seeking postconviction

relief under Rule 37.1 of the Arkansas Rules of Criminal Procedure. The circuit court denied

the petition, and Blasingame appeals. On appeal, Blasingame argues that the court abused

its discretion in disposing of his Rule 37 petition and in failing to appoint counsel to

represent him at his Rule 37 hearing. He also contends that the court erred in finding that

his trial counsel provided effective assistance. We affirm.

On February 7, 2024, Blasingame pled guilty in the Sebastian County Circuit Court

to one count each of aggravated robbery, first-degree criminal mischief, felony theft of

property, and fleeing. He was sentenced as a habitual offender with four or more prior

felonies, and he received an aggregate sentence of forty years in prison in addition to twenty

years’ suspended imposition of sentence (SIS). Pursuant to the plea agreement, the court ordered his sentences to be served concurrently to a fifty-year sentence he was serving for a

conviction in Crawford County.

On March 6, his attorney addressed the court, stating, “[Blasingame] wrote me a letter

after he pled and told me that he did not understand why he was being charged with more

than what he thought he was going to be charged with and he wanted to withdraw his plea.”

A motion had not been filed, so the court would not hear the matter that day. On March 7,

Blasingame filed a pro se Rule 37 petition. First, he alleged that his conviction was obtained

through the use of a “coerced confession” in that he was told “the 40 [years] would run

concurrent on ½ of ½ with 50 [years] from Van Buren”; second, that the charges in Crawford

County and Sebastian County were the same charges and violated double jeopardy; and

third, that he entered the guilty plea while he was mentally incompetent, claiming that he

was “under severe stress [at the] time of signing [and] also on mental[-]health medication.”

Blasingame concluded his claims by stating, “I’d never signed if I knew they was giving me

100% on 40 [years].”

The court reconvened on March 20 for a hearing on Blasingame’s petition.

Blasingame testified he pled guilty with “the understanding” that he “would do around a

12[-]year sentence before going up for parole.” When asked by the circuit court whether the

Crawford County sentence was a “100 per cent sentence[,]” Blasingame said, “Once I had

gotten the charge over here[,] they give it to me on 100 instead of 70 per cent.”

The circuit court inquired further, asking Blasingame whether he was aware that the

different charges required a different percentage of service. Blasingame responded, “Yes, sir;

2 Your Honor; but [ ] you told me that it was going to run concurrent and that my T.E. day

wouldn’t change. I assumed that it was also on the additional 50 that Van Buren was.”

The State called Blasingame’s former defense counsel (“counsel”), who represented

him when he pled guilty to the Sebastian County charges. Counsel testified that Blasingame

contacted him and told him he wanted any time he received in the Sebastian County case to

run concurrently with the fifty-year sentence he had received in Crawford County. Counsel

stated that—in addition to the new Sebastian County charges—Blasingame also had a pending

revocation “with 98 years of exposure.” Counsel said he contacted the prosecutor handling

Blasingame’s case, and they had agreed that the Sebastian County sentence would run

concurrently with the Crawford County sentence. Counsel said that after securing this

agreement, he informed Blasingame of that fact. Counsel also informed Blasingame that,

regarding his forty-year Crawford County sentence, he would be required to do “70 percent

on 40 years and that is 28 years.” Counsel also said that, as part of the negotiated guilty plea,

the State agreed to withdraw the pending revocation petition.

During direct examination of counsel, the State introduced a document that detailed

the possible penalties for Blasingame’s old and new charges: Blasingame’s possible exposure

“on both old and new cases [was] life in prison plus 198 years.” On cross-examination,

counsel explained that since Blasingame’s exposure was significant, the negotiated guilty plea

was “a very good deal”; otherwise, Blasingame faced the prospect of spending his entire life

in prison. When questioned further by the court, Counsel reiterated that Blasingame talked

about his “Crawford County stuff being half of a half[.]” Counsel said that his advice was

3 limited to answering the question, “Is this going to run concurrent?” Counsel restated his

answer to Blasingame: “I said, ‘Yes, it will run concurrent, but you will do more time.’”

At the conclusion of the testimony, the circuit court ruled from the bench that it

found defense counsel’s version of events more credible than Blasingame’s version. On

March 21, the circuit court entered an order detailing the court’s finding that Blasingame

was informed that his Sebastian County sentence would run concurrently with his Crawford

County sentence and would be subject to the requirement that he serve 70 percent of the

Sebastian County sentence before being eligible for parole. Accordingly, the circuit court

denied appellant’s Rule 37 petition. This appeal followed.

This court will not reverse a circuit court’s decision granting or denying

postconviction relief unless it is clearly erroneous. Houghton v. State, 2015 Ark. 252, 464

S.W.3d 922. A finding is clearly erroneous when, although there is evidence to support it,

the appellate court, after reviewing the entire evidence, is left with the definite and firm

conviction that a mistake has been committed. Id.

We review a defendant’s ineffective-assistance-of-counsel claims using the two-step

analysis outlined in Strickland v. Washington, 466 U.S. 668 (1984). Under Strickland, a

petitioner is required to show that his trial counsel’s performance was deficient and that the

deficiency prejudiced his defense. Id.

Regarding the threshold issue of deficiency, we presume that a trial counsel’s

performance was sufficient. Holland v. State, 2022 Ark. 138, 645 S.W.3d 318. To overcome

that strong presumption, the petitioner must demonstrate specific acts and omissions that,

4 when viewed from the trial counsel’s perspective over the course of the trial, could not have

been the result of reasonable professional judgment. Id. at 2, 645 S.W.3d at 321. Allegations

without factual substantiation are insufficient. Thomas v. State, 2022 Ark. 12, 637 S.W.3d

268. Furthermore, merely conclusory statements that one’s counsel was ineffective cannot

be the basis for postconviction relief. Id.

As for the remaining issue of prejudice, a petitioner must affirmatively demonstrate

that the deficiency resulted in a prejudicial outcome. Holland, 2022 Ark. 138, at 2, 645

S.W.3d at 321. He must show that there is a reasonable probability that the fact-finder’s

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2025 Ark. App. 412 (Court of Appeals of Arkansas, 2025)

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