Thomas Crockett v. Dexter Payne, Director, Arkansas Division of Correction

── Thomas Crockett v. Dexter Payne, Director, Arkansas Division of Correction ── Court: Supreme Court of Arkansas Date: April 16, 2026 Category: General Cite as 2026 Ark. 62 SUPREME COURT OF ARKANSAS No. CV-25-425 Opinion Delivered: April 16, 2026 THOMAS CROCKETT APPELLANT PRO SE APPEAL FROM THE JEFFERSON COUNTY CIRCUIT COURT; MOTION TO FILE V. BELATED REPLY BRIEF [NO. 35CV-25-25] DEXTER PAYNE, DIRECTOR, ARKANSAS DIVISION OF HONORABLE JODI RAINES CORRECTION DENNIS, JUDGE APPELLEE AFFIRMED; MOTION MOOT. RHONDA K. WOOD, Associate Justice In 1983, Thomas Crockett pleaded guilty to first-degree murder and was sentenced to life imprisonment. Later he filed a Rule 37 petition alleging ineffective assistance of counsel.1 We denied relief.2 Next, Crockett filed a petition for writ of habeas corpus contending again that his counsel was ineffective and that Crockett was unaware he had a defense of justification.3 We denied relief.4 Before us now is Crockett’s appeal from the denial of his second petition for writ of habeas corpus. Once again, he argues for habeas 1 Crockett v. State, 282 Ark. 582, 669 S.W.2d 896 (Crockett I) (1984). 2 Id. at 584, 669 S.W.2d at 898. 3 Crockett v. Kelley, 2020 Ark. 26, at 1 (Crockett II). 4 Id. at 3. relief based on grounds outside the scope of a habeas proceeding; thus, we affirm the circuit court’s denial of his petition.5 Previously, we noted that Crockett pleaded guilty in open court, admitting that he robbed and murdered James Williams.6 In the appeal from his first habeas petition, we explained that habeas proceedings are not a means to challenge the sufficiency of the evidence in a case, and a habeas action does not afford a petitioner the opportunity to retry his or her case.7 Crockett again fails to establish grounds for the writ. We will affirm a circuit court’s decision on a petition for writ of habeas corpus unless it is clearly erroneous.8 The decision is clearly erroneous when the appellate court is left with the definite and firm conviction that there has been a mistake.9 A writ of habeas corpus is proper when a judgment and commitment order is invalid on its face or when a circuit court lacks jurisdiction over the cause.10 A trial court has subject-matter jurisdiction to hear and determine cases involving violations of criminal statutes and has personal jurisdiction over offenses committed within 5 Crockett filed a motion to file belated reply brief and tendered a reply brief. Because we affirm the circuit court’s order, the motion is moot. 6 Crockett I, 282 Ark. at 584, 669 S.W.2d at 898. 7 Crockett II, 2020 Ark. 26, at 3. 8 Burks v. Payne, 2024 Ark. 80, at 2, 687 S.W.3d 798, 800. 9 Id. at 3, 687 S.W.3d at 800–01. 10 Finney v. Kelley, 2020 Ark. 145, at 3, 598 S.W.3d 26, 28. 2 the county over which it presides.11 The circuit court’s inquiry into the validity of the judgment is limited to the face of the commitment order.12 In his petition for habeas corpus, Crocket raised the following issues: (1) whether his sentence is illegal because the charging document did not identify the underlying felony that would support the first-degree murder charge; (2) whether there was a fundamental error in his conviction because a formal charge of first-degree murder was not filed, only a capital- murder charge, and (3) whether he was denied his Sixth Amendment right to counsel during his plea proceedings. None provide a basis for granting the writ. Crockett attacks the underlying judgment by claiming that his