TRAMMEL v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION (Majority, with Dissenting)
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In this case, the Supreme Court of Arkansas was asked to consider an appeal by Maurice Trammel, who was challenging the denial of his petition to proceed in forma pauperis in seeking a declaratory judgment and a writ of mandamus. Trammel had been sentenced to 240 months' imprisonment for various crimes and was designated as a habitual offender. He sought to challenge his habitual offender status, arguing that there was no proof offered by the State that demonstrated he had committed the necessary number of felonies to be classified as such. He further argued that his sentence should be declared illegal, which would effectively reduce his period of parole eligibility.
The Supreme Court of Arkansas held that Trammel did not state a colorable cause of action and that his petition was effectively a collateral attack on his sentence, which should have been raised in timely postconviction petitions. The court noted that Trammel was charged as a habitual offender and pleaded guilty to all the charges, including his habitual-offender status. His challenge to the sufficiency of the evidence supporting his habitual offender status was not a jurisdictional issue and was therefore waived by his guilty plea. Moreover, the court observed that the Department of Correction had no authority to modify a sentence imposed by a circuit court.
Hence, the court affirmed the circuit court's denial of Trammel's in forma pauperis petition, finding no abuse of discretion in the circuit court's conclusion that Trammel had failed to state a justiciable controversy that would entitle him to declaratory relief.
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