Edward Joseph Reynolds v. State of Arkansas

Summary

The court declined to dismiss Reynolds's appeal because the record did not establish whether his postconviction petition was timely mailed under the prison-mailbox provision. Because the circuit clerk failed to include the petition's envelope in the record, the court remanded for a supplemental record or, if the envelope was unavailable, a hearing to settle the record and determine the relevant dates. The court also explained that a filing may be treated as received when tendered if a defect involving pauper status is timely cured after a reasonable opportunity. Justice Wood, joined by the Chief Justice and Justice Womack, dissented and would have dismissed the appeal because Reynolds could not prevail on his ineffective-assistance claims.