Bryant v. Hobbs

Summary

The court affirmed dismissal of Bryant’s habeas petition because he did not establish that the judgment was facially invalid or that the trial court lacked jurisdiction. Although a double-jeopardy claim may be cognizable in habeas proceedings when an illegal sentence appears on the face of the commitment order, Bryant failed to show that his possession and manufacturing convictions arose from the same conduct. The evidence supported separate acts: manufacturing occurred in an operational laboratory, while possession was based on methamphetamine found under a bed.