Kenny J. Travis, Jr. v. Dexter Payne, Arkansas Division of Correction

── Kenny J. Travis, Jr. v. Dexter Payne, Arkansas Division of Correction ── Court: Supreme Court of Arkansas Date: April 16, 2026 Category: General Cite as 2026 Ark. 65 SUPREME COURT OF ARKANSAS No. CV-25-424 Opinion Delivered: April 16, 2026 KENNY J. TRAVIS, JR. APPELLANT PRO SE APPEAL FROM THE JEFFERSON COUNTY CIRCUIT COURT V. [NO. 35CV-25-166] HONORABLE JODI RAINES DEXTER PAYNE, DIRECTOR, DENNIS, JUDGE DIVISION OF CORRECTION APPELLEE AFFIRMED. BARBARA W. WEBB, Justice Appellant Kenny J. Travis, Jr. appeals from the circuit court’s order denying his petition for writ of habeas corpus filed pursuant to Arkansas Code Annotated sections 16- 112-101 to -123 (Repl. 2016) in the county where he is incarcerated. In the petition, Travis alleged due-process violations during the course of his criminal trial and claimed a miscarriage of justice resulting in his conviction. In addition, Travis claimed a violation of Brady v. Maryland, 373 U.S. 83 (1963) in connection with a coroner’s report. The circuit court denied the petition on the basis that Travis’s claims were not cognizable in habeas proceedings and had therefore failed to establish probable cause that Travis was being illegally detained. We affirm. Travis was convicted by a Mississippi County jury of capital murder and aggravated robbery committed in June 2005 and was sentenced to life and ten years’ imprisonment, respectively. Travis appealed, and his conviction and sentences were affirmed. Travis v. State, 371 Ark. 621, 269 S.W.3d 341 (2007). A circuit court’s decision on a petition for writ of habeas corpus will be upheld unless it is clearly erroneous. Lowery v. Payne, 2023 Ark. 85, 665 S.W.3d 223. A decision is clearly erroneous when, although there is evidence to support it, the appellate court, after reviewing the entire evidence, is left with the definite and firm conviction that a mistake has been made. Id. 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. Jefferson v. Payne, 2025 Ark. 174, 722 S.W.3d 769. Jurisdiction is the power of the court to hear and determine the subject matter in controversy. Id. When the circuit court has personal jurisdiction over the appellant and also has jurisdiction over the subject matter, the court has authority to render the judgment. Id. Proceedings for the writ do not require an extensive review of the record of the trial proceedings, and the circuit court’s inquiry into the validity of the judgment is limited to the face of the commitment order. Id. Unless the petitioner can show that the commitment order was invalid on its face, there is no basis for finding that a writ of habeas corpus should issue. Id. In the petition filed in the circuit court, Travis raised the following allegations that he was deprived of due process during the course of his criminal trial: (1) there were inconsistencies in evidence establishing the victim’s time of death; (2) the collection of fingerprint evidence was defective; (3) certain witness testimony was inconsistent with other 2 evidence gathered during the investigation; (4) the coroner’s report addressing time of death was withheld in violation of Brady; (5) the coroner who authored the report did not testify at trial, depriving defense of the right to confront an adverse witness; (6) time of death reported by the coroner was improperly calculated. On appeal, Travis raises additional due-process claims and includes new allegations disputing the reliability of the evidence supporting his conviction that were not raised in his