Wilson v. State of Arkansas

CourtDistrict Court, W.D. Arkansas
DecidedMay 19, 2021
Docket6:19-cv-06073
StatusUnknown

This text of Wilson v. State of Arkansas (Wilson v. State of Arkansas) is published on Counsel Stack Legal Research, covering District Court, W.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wilson v. State of Arkansas, (W.D. Ark. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS HOT SPRINGS DIVISION

LAMAR DANIEL WILSON PETITIONER

v. Case No. 6:19-cv-6073

WENDY KELLY, Director, Arkansas Department of Correction RESPONDENT

ORDER Before the Court is the Report and Recommendation filed by the Honorable Barry A. Bryant, United States Magistrate Judge for the Western District of Arkansas. ECF No. 16. Judge Bryant recommends that Petitioner Lamar Daniel Wilson’s Petition for Writ of Habeas Corpus pursuant to 28 U.S.C. § 2254 be denied. Petitioner has responded with objections. ECF No. 17. The Court finds the matter ripe for consideration. I. BACKGROUND Petitioner was charged in the Circuit Court of Garland County, Arkansas, with rape of a victim under the age of fourteen. On August 10, 2015, a trial was held regarding this charge. Before the State of Arkansas (“State”) rested its case, it moved to amend the criminal information to conform to the proof. At the conclusion of testimony, the court instructed the jury that second-degree sexual assault is a lesser-included offense of rape and that sexual indecency with a child is a lesser-included offense of both rape and second-degree sexual assault. The jury found Petitioner not guilty of rape. However, despite the court’s instruction to consider sexual indecency only if it found that Petitioner had not committed second-degree sexual assault, the jury returned guilty verdicts for both the sexual assault and sexual indecency offenses. After discussions with the attorneys and polling the jury, the trial court set aside the verdict for sexual indecency with a child. Petitioner was sentenced to twenty (20) years imprisonment for the second-degree sexual assault conviction. Petitioner’s attorney filed a motion for a new trial, arguing that second-degree sexual assault was not a lesser-included offense of rape and that the jury verdict should be set aside. The State responded by admitting that the sexual assault charge was not a lesser included offense

of rape but asked the trial court to enter the jury’s determination of guilt on the sexual indecency charge. On September 15, 2015, a hearing was scheduled regarding Petitioner’s motion for a new trial. At the hearing, Petitioner’s attorney informed the Court that Petitioner and the State had reached an agreement to allow Petitioner to plead nolo contendere, or no contest, to the offense of sexual indecency with a child. The plea agreement was signed by Petitioner, his attorney, and the prosecutor. Petitioner’s prior twenty-year sentence was vacated. Based on the plea agreement, Petitioner was sentenced to six (6) years imprisonment for sexual indecency with a child. Petitioner filed a pro se motion to vacate the state court judgment, arguing that he had

never been charged with the offense of sexual indecency with a child. The trial court denied the motion, and Petitioner appealed to the Arkansas Court of Appeals. Petitioner’s attorney filed a no-merit brief, and Petitioner did not file pro se points for reversal. The Arkansas Court of Appeals affirmed Petitioner’s conviction. Petitioner then filed a Rule 37 petition with the trial court arguing that his trial counsel was ineffective. The trial court denied the Rule 37 petition. Plaintiff appealed to the Arkansas Court of Appeals. The Arkansas Court of Appeals affirmed the trial court’s denial of post- conviction relief. Petitioner then filed a belated petition for review by the Arkansas Supreme Court, which was denied. On June 27, 2019, Petitioner filed the instant habeas petition with this Court.1 In the instant petition, Plaintiff makes claims regarding double jeopardy, lack of jurisdiction, due process, and the Sixth Amendment. He seeks a “full reversal of current conviction and sentence; absolute bar to relative prosecutions; and absolute destruction, or permanent seal, of all court,

law enforcement, and applicable agencies, records relating to this matter.” ECF No. 1, p. 15. Judge Bryant issued a Report and Recommendation in which he recommended that the Court deny the instant petition and dismiss the case, and Petitioner has filed objections. ECF Nos. 16, 17. II. STANDARD OF REVIEW A federal court may grant a writ of habeas corpus if the state court’s decision “was contrary to, or involved an unreasonable application of, clearly established Federal law, as determined by the Supreme Court of the United States.” 28 U.S.C. § 2254(d)(1). A state court acts contrary to clearly established federal law if it applies a legal rule that contradicts the Supreme Court’s prior holdings or if it reaches a different result from one of that Court’s cases

despite confronting indistinguishable facts. Williams v. Taylor, 529 U.S. 362, 405-06 (2000). “[I]t is not enough for [the court] to conclude that, in [its] independent judgment, [it] would have applied federal law differently than state court; the state court’s application must have been objectively unreasonable.” Rousan v. Roper, 436 F.3d 951, 956 (8th Cir. 2006). III. DISCUSSION In the Report and Recommendation (ECF No. 16), Judge Bryant found that the state court’s decision on the following issues was not contrary to and did not involve an unreasonable application of clearly established federal law: (1) Petitioner was not subjected to double

1 When he filed the petition, Petitioner was no longer incarcerated in the Arkansas Division of Correction and was out on parole. However, a parolee remains “in custody,” and thus parole status does not deprive the Court of jurisdiction over habeas corpus petition. Jones v. Jerrsion, 20 F.3d 849, 852 n.2 (8th Cir. 1994). jeopardy; (2) the state trial court had jurisdiction to accept and enter Petitioner’s no contest plea to sexual indecency with a child; (3) Petitioner cannot attack his guilty plea by arguing that there was no valid charging instrument; and (4) Petitioner’s plea was voluntary and his counsel was not ineffective. Petitioner makes the following objections: (1) he was subjected to double

jeopardy because he was originally acquitted of sexual indecency with a child; (2) there exists “no tangible/extraneous evidence” to support his conviction; and (3) there was no valid charging instrument regarding his guilty plea to sexual indecency with a child. These objections are arguments that Petitioner made in his habeas petition, and his objections do not specifically address portions of the Report and Recommendation that he considers erroneous. Nevertheless, the Court will address each objection in turn. A. Double Jeopardy Petitioner claims that he was convicted twice for the same offense because his conviction for sexual indecency with a child had been vacated2 when he pleaded no contest to the same charge. Thus, he contends that his plea was a violation of double jeopardy. The Arkansas Court

of Appeals found that Petitioner’s no contest plea to sexual indecency with a child was not a second conviction for the same offense because his plea occurred after he had filed a motion for new trial. The court noted that Petitioner entered his no contest plea to avoid being tried for the greater offense of second-degree sexual assault. The court further noted that by virtue of the plea, Petitioner stands convicted of only a single count of sexual indecency with a child, for which he is serving a six-year sentence for only that offense.

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Related

Lockhart v. Nelson
488 U.S. 33 (Supreme Court, 1988)
Williams v. Taylor
529 U.S. 362 (Supreme Court, 2000)
United States v. Harvey Andrew Rea
300 F.3d 952 (Eighth Circuit, 2002)
Wilson v. State
475 S.W.2d 543 (Supreme Court of Arkansas, 1972)

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Wilson v. State of Arkansas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wilson-v-state-of-arkansas-arwd-2021.