Mitchell v. Kelley

Summary

The court affirmed the denial of Mitchell’s habeas petition because none of his claims established that his conviction was facially invalid or that the trial court lacked jurisdiction. His ineffective-assistance claims required an inquiry beyond the face of the commitment, and his actual-innocence claims were unauthorized sufficiency-of-the-evidence challenges outside habeas proceedings. The court also held that the absence of appointed counsel during Rule 37 proceedings did not make the judgment invalid.