Shawn Trevell Rainer v. Director, Arkansas Department of Correction

Summary

The court affirmed the denial of Rainer’s habeas petition because his challenge to the habitual-offender enhancement was not cognizable in habeas proceedings and, in any event, did not establish an ex post facto violation. The court held that the relevant enhancement statute was in effect when Rainer committed the later murder and could use his earlier conviction to increase the sentence for the later offense.