Rolandis Chatmon v. Dexter Payne

Summary

The Supreme Court of Arkansas affirmed the denial and dismissal of Rolandis Chatmon’s habeas petition challenging the authority of the judge who presided over his criminal trial. The court held that the oath-of-office allegation was not cognizable in habeas proceedings because it did not establish facial invalidity of the judgment or a jurisdictional defect, and that the judge was at least a de facto official whose acts were valid in a collateral challenge. The court also concluded that the circuit court’s ruling was not clearly erroneous.