Ray O'neal v. Dexter Payne

Summary

The court reversed the denial of habeas relief because the sentencing order did not identify the subsection under which the appellant pleaded guilty to third-degree domestic battering. That omission prevented a reliable determination from the face of the order whether the sentence was facially valid, including whether two enhancement statutes had been impermissibly applied. The case was remanded for entry of a complete sentencing order.