Oscar Willingham v. State of Arkansas

2021 Ark. 177, 631 S.W.3d 558
CourtSupreme Court of Arkansas
DecidedOctober 14, 2021
StatusPublished
Cited by10 cases

This text of 2021 Ark. 177 (Oscar Willingham v. State of Arkansas) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Oscar Willingham v. State of Arkansas, 2021 Ark. 177, 631 S.W.3d 558 (Ark. 2021).

Opinion

Reason: I attest to the accuracy Cite as 2021 Ark. 177 and integrity of this document Date: 2022.06.13 15:53:17 -05'00' Adobe Acrobat version: SUPREME COURT OF ARKANSAS 2022.001.20117 No. CR-21-62

Opinion Delivered: October 14, 2021 OSCAR WILLINGHAM APPELLANT PRO SE APPEAL FROM THE CLARK COUNTY CIRCUIT COURT [NO. 10CR-11-151] V. HONORABLE CHARLES A. STATE OF ARKANSAS YEARGAN, JUDGE APPELLEE REVERSED AND REMANDED TO CORRECT SENTENCING ORDER.

COURTNEY RAE HUDSON, Associate Justice

Appellant, Oscar Willingham, appeals from the circuit court’s denial of his pro se

petition to correct an illegal sentence pursuant to Arkansas Code Annotated section 16-90-

111 (Repl. 2016). For reversal, Willingham asserts that (1) the sentencing order entered in

his case was illegal on its face in that the sentence imposed for theft of property exceeded

the statutory maximum for a Class D felony, and (2) the order further reflected that he was

convicted as a habitual offender even though the prosecution agreed to dismiss the habitual-

offender charges. We reverse and remand to the circuit court.

On October 22, 2012, Willingham pled guilty to one count of aggravated residential

burglary, one count of aggravated robbery, one count of kidnapping, and one count of theft

of property. The plea-hearing transcript that is part of this record reflects that pursuant to

the negotiated plea deal, the prosecution agreed to withdraw the habitual-offender charges

against Willingham. The plea-hearing transcript further demonstrates that Willingham was advised that he had agreed to plead guilty to two Class Y felonies for aggravated residential

burglary and aggravated robbery and two Class B felonies for kidnapping and theft of

property. Willingham was sentenced to 288 months’ or 24 years’ imprisonment for

aggravated residential burglary, 120 months’ or 10 years’ imprisonment for aggravated

robbery, 240 months’ or 20 years’ suspended imposition of sentence for kidnapping, and

240 months’ or 20 years’ imprisonment for theft of property, for an aggregate sentence of

648 months’ or 54 years’ imprisonment.

When Willingham committed the offenses, Arkansas Code Annotated section 5-36-

103(b)(3)(A) (Supp. 2011) defined a Class D theft-of-property offense as theft of property

valued between $1,000 and $5,000. Theft of property was a Class B offense if the property

was obtained by threat. Ark. Code Ann. § 5-36-103(b)(1)(B). Pursuant to Arkansas Code

Annotated section 5-4-401(a)(5) (Repl. 2006), a Class D felony carried a maximum sentence

of six years’ imprisonment. A Class B felony was punishable by five to twenty years in

prison. Ark. Code Ann. § 5-4-401(a)(3).

The original 2012 sentencing order reflects that Willingham committed the offenses

in September 2011 and that he was convicted as a habitual offender in contravention of the

plea agreement. Furthermore, the sentencing order indicates that Willingham’s theft-of-

property offense was based on the value of the property––more than $1,000 and less than

$5,000––in violation of Arkansas Code Annotated section 5-36-103(b)(3)(A). Finally, the

order classified the theft-of-property offense as a Class D offense.

On July 15, 2020, Willingham filed his first petition to correct an illegal sentence

alleging that his sentence exceeded the penalty for a Class D felony. In response to the

2 petition, the circuit court entered an amended sentencing order nunc pro tunc in July 2020

that designated the theft offense as a Class B felony but did not change the description of

the offense or the code section that supported a conviction for a Class B felony. Willingham

filed a second petition in November 2020 again challenging his theft-of-property sentence

and additionally alleging that the order incorrectly reflected that he had been convicted as a

habitual offender––charges that had been withdrawn by the prosecution. The circuit court

subsequently denied Willingham’s petition on the basis that an amended order had been

entered in the case. Willingham filed a timely notice of appeal.

The circuit court’s decision to deny relief pursuant to section 16-90-111 will not be

overturned unless that decision is clearly erroneous. Millsap v. State, 2020 Ark. 38. Under

section 16-90-111, 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 made. Id.

Section 16-90-111(a) provides authority to a circuit court to correct an illegal

sentence at any time. Redus v. State, 2019 Ark. 44, 566 S.W.3d 469. An illegal sentence is

one that is illegal on its face. Jackson v. State, 2018 Ark. 209, 549 S.W.3d 346. A sentence is

illegal on its face when it is void because it is beyond the circuit court’s authority to impose

and gives rise to a question of subject-matter jurisdiction. Id. Sentencing is entirely a matter

of statute in Arkansas. Fischer v. State, 2017 Ark. 338, 532 S.W.3d 40. The petitioner seeking

relief under section 16-90-111(a) carries the burden of demonstrating that his or her

sentence was illegal. Redus, 2019 Ark. 44, 566 S.W.3d 469. The general rule is that a

sentence imposed within the maximum term prescribed by law is not illegal on its face.

3 McArty v. State, 2020 Ark. 68, 594 S.W.3d 54. A circuit court has subject-matter jurisdiction

to hear and determine cases involving violations of criminal statutes, and typically, trial error

does not implicate the jurisdiction of the circuit court or, as a consequence, implicate the

facial validity of the judgment. Id.

Willingham first alleged in his petition filed in the circuit court and in his argument

on appeal that his sentence for theft of property exceeded the maximum for a Class D felony

as described in the sentencing order. A circuit court has the power to correct clerical errors

nunc pro tunc so that the record speaks the truth. Barnett v. State, 2020 Ark. 181, 598

S.W.3d 835. Pursuant to Rule 60(b) of the Arkansas Rules of Civil Procedure, a circuit

court may at any time correct clerical mistakes in judgments, decrees, orders, or other parts

of the record and errors therein arising from oversight or omission. Id. A circuit court’s

power to correct mistakes or errors is to make the record speak the truth, but not to make

it speak what it did not speak but ought to have spoken. State v. Rowe, 374 Ark. 19, 285

S.W.3d 614 (2008).

Here, the record demonstrates that the information charged Willingham with theft

of property valued between $1,000 and $5,000. However, the information additionally

charged Willingham for committing the theft “with the purpose of depriving the owner of

the property by threat of serious physical injury.” The information further designates the

theft charge as a Class B felony that was properly designated as such in accordance with

section 5-36-103(b)(1)(B), which states in pertinent part that theft of property is classified as

a Class B felony if the property is obtained by threat of serious injury. Moreover, the

transcript of the plea hearing reveals that Willingham had been advised that he was being

4 charged with a Class B felony, which carried a maximum term of imprisonment of twenty

years for the theft-of-property offense; and following Willingham’s plea, the court

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2021 Ark. 177, 631 S.W.3d 558, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oscar-willingham-v-state-of-arkansas-ark-2021.