Malachi Muhammad v. Dexter Payne

Summary

The Supreme Court of Arkansas affirmed the dismissal of Muhammad’s habeas petition. It held that his claim challenging the validity of the firearm conviction and guilty plea was a collateral attack that had to be brought under Rule 37.1, and that the time for seeking Rule 37 relief had expired. The court also noted that Muhammad failed to challenge the circuit court’s procedural grounds for dismissal.