Supreme Court of Arkansas
Corelanius Phillips v. Aundrea Culclager
June 17, 20212021 Ark. 149
Summary
The court affirmed dismissal of Phillips's habeas petition because his challenge to being tried by an eleven-member jury alleged a trial or due-process error, not a facially invalid judgment or lack of subject-matter jurisdiction. The court held that the claim could have been pursued on direct appeal or through a timely postconviction proceeding, but was not cognizable in habeas proceedings. The circuit court therefore did not clearly err in dismissing the petition.