Tony Franklin Wilson v. State of Arkansas

Summary

The court affirmed dismissal of Wilson's habeas petition because his actual-innocence claim did not fit either statutory avenue for habeas relief and he did not show that his judgment was facially invalid or that the circuit court lacked jurisdiction. His claimed recantation challenged the sufficiency of the evidence, which is not cognizable in habeas proceedings, and his sentence was authorized by the statute in effect when he committed the offense. The court also held that no evidentiary hearing was required because Wilson failed to establish probable cause for issuance of the writ.