Jason Adkins v. State of Arkansas
CourtCourt of Appeals of Arkansas
Date FiledSeptember 30, 2026
StatusPublished
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Full Opinion
Cite as 2026 Ark. App. 457
ARKANSAS COURT OF APPEALS
DIVISION IV
No. CR-25-525
JASON ADKINS Opinion Delivered September 30, 2026
APPELLANT
APPEAL FROM THE WASHINGTON
V. COUNTY CIRCUIT COURT
[NO. 72CR-20-282]
STATE OF ARKANSAS
APPELLEE HONORABLE JOANNA TAYLOR,
JUDGE
DISMISSED
MIKE MURPHY, Judge
Appellant Jason Adkins was convicted in the Washington County Circuit Court of
four counts of first-degree sexual assault. Adkins appealed, challenging the circuit court’s
denial of his continuance request and its allowing the State to amend the criminal
information six days before trial. We affirmed, and Adkins was sentenced to an aggregate
term of eighty years’ imprisonment. See Adkins v. State, 2024 Ark. App. 200, 686 S.W.3d 599.
The mandate was issued on October 1, 2024.
After the mandate was issued, Adkins filed a pro se petition for postconviction relief
pursuant to Ark. R. Crim. P. 37.1. The petition was not verified as required by Rule 37.1(c).
Therefore, the circuit court entered an order dismissing the petition on December 9, 2024.
On May 2, 2025, Adkins filed a second pro se Rule 37.1 petition. This second petition
was verified as required by Rule 37.1(c), but the circuit court found it was untimely under
Ark. R. Crim. P. 37.2(c)(ii) and entered an order dismissing the petition for lack of
jurisdiction on May 22, 2025. This appeal followed.
Rule 37.2(c)(ii) requires a petitioner who appeals a judgment of conviction to file the
postconviction petition “within sixty (60) days of the date the mandate is issued by the
appellate court.” Adkins’s second Rule 37.1 petition was not timely under Rule 37.2(c)(ii)
because the mandate was issued on October 1, 2024, and the petition was filed on May 2,
2025, well past the sixty-day deadline.
The time limitations imposed in Rule 37.2 are jurisdictional, and if those
requirements are not met, a circuit court lacks jurisdiction to grant postconviction relief.
Williamson v. State, 2012 Ark. 170, at 4. When the circuit court lacks jurisdiction, the
appellate court also lacks jurisdiction. Id.
Adkins did not file a timely petition for postconviction relief that was sufficient to
confer jurisdiction on the circuit court to consider his claims for relief. Accordingly, we must
dismiss the appeal because the circuit court was, and therefore this court is, without
jurisdiction to consider his claims.
Dismissed.
GLADWIN and THYER, JJ., agree.
Jason Adkins, pro se appellant.
Tim Griffin, Att’y Gen., by: Rebecca Kane, Ass’t Att’y Gen., for appellee.
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