SIMS v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION (Majority, with Dissenting)
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In this case, the Supreme Court of Arkansas affirmed the denial of declaratory judgment and writ of mandamus petitions filed by Charles Sims, an inmate in the Arkansas Department of Correction (ADC). Sims had sought a declaration that he was eligible for parole, contrary to the determination made by ADC. The court affirmed the circuit court's finding that Sims was ineligible for parole according to the Arkansas Code.
Sims had pleaded guilty to first-degree murder in 1995 and was paroled in 2007. In 2010, he pleaded guilty to first-degree battery and kidnapping, and was sentenced to concurrent terms of 180 months' imprisonment to run concurrently with his remaining sentence for first-degree murder. ADC records applied section 16-93-609 to Sims’s sentence for battery and kidnapping, determining him ineligible for parole.
The court held that Sims had failed to establish a justiciable controversy or that he had a legal interest in the controversy, two prerequisites for declaratory relief. The court also noted that parole eligibility determinations fall within the purview of ADC, not the judiciary. The court further held that the absence of a reference to the parole-eligibility statute in the judgment did not constitute a requirement for parole eligibility.
The court also dismissed Sims's argument that section 5-4-501(d)(2) was inapplicable to him, holding that the court has applied the relevant sections when the prior conviction consisted of only one offense. The court concluded that Sims had not established a right to parole eligibility, and therefore had no basis for the issuance of a writ of mandamus. The court affirmed the circuit court's decisions, ruling it did not clearly err or abuse its discretion when it denied and dismissed Sims's petitions for declaratory judgment and writ of mandamus.
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