Jerry W. Walker v. Dexter Payne

Summary

The court affirmed the denial and dismissal of Walker’s habeas petition because neither his challenge to the jury instructions nor his self-defense claim established that the judgment was facially invalid or that the trial court lacked jurisdiction. The court held that jury-instruction errors are trial errors outside the scope of habeas review and that the self-defense law in effect when Walker committed the murder controlled his actual-innocence claim. The court reviewed the circuit court’s decision for clear error.