Full Opinion

Cite as 2026 Ark. 186 SUPREME COURT OF ARKANSAS No. CV-26-360 Opinion Delivered: November 12, 2026 JASTER LEE MARBLEY APPELLANT PRO SE APPEAL FROM THE LINCOLN COUNTY CIRCUIT COURT V. [NO. 40CV-25-103] DEXTER PAYNE, DIRECTOR, HONORABLE JODI RAINES ARKANSAS DIVISION OF DENNIS, JUDGE CORRECTION APPELLEE AFFIRMED. RHONDA K. WOOD, Associate Justice Jaster Lee Marbley appeals from the denial and dismissal of his petition for writ of habeas corpus filed under Arkansas Code Annotated section 16-112-101 (Repl. 2016). The circuit court found that Marbley had failed to demonstrate that he was being illegally held. We affirm. A jury found Marbley guilty of aggravated robbery, and he was sentenced to life imprisonment. We affirmed on direct appeal. Hudson v. State, No. CR83-112 (Ark. Feb. 21, 1984) (unpublished per curiam).1 In his habeas petition, Marbley claimed error because he did not receive a hearing before a magistrate prior to being bound over for trial. His petition was denied, and he appeals. As Marbley’s claim is an allegation of trial error rather than lack of jurisdiction, we affirm. 1 The case was styled in the name of his codefendant, Jimmie Lee Hudson. We will affirm a circuit court’s decision on a petition for writ of habeas corpus unless it is clearly erroneous. Burks v. Payne, 2024 Ark. 80, at 2, 687 S.W.3d 798, 800. The decision is clearly erroneous when the appellate court is left with the definite and firm conviction that there has been a mistake. Id. at 3, 687 S.W.3d at 800–01. 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. Finney v. Kelley, 2020 Ark. 145, at 3, 598 S.W.3d 26, 28. A trial court has subject-matter jurisdiction to hear and determine cases involving violations of criminal statutes and has personal jurisdiction over offenders who have committed said violations within the county over which it presides. Fuller/Akbar v. Payne, 2021 Ark. 155, at 4, 628 S.W.3d 366, 368. The circuit court’s inquiry into the validity of the judgment is limited to the face of the commitment order. Id. at 3, 628 S.W.3d at 368. Again, Marbley alleges that he is entitled to habeas relief because he did not receive a preliminary hearing before a magistrate judge. He contends this violates the Arkansas Rules of Criminal Procedure and his right to due process. According to Marbley, this procedural error deprived the trial court of jurisdiction. Marbley is mistaken. Assertions of trial error and due-process violations do not implicate the trial court’s jurisdiction. Ratliff v. Kelley, 2018 Ark. 105, 541 S.W.3d 408. Allegations of improper arraignment are considered claims of trial error that are not cognizable in habeas proceedings. Anderson v. Kelley, 2018 Ark. 222, 549 S.W.3d 913. Marbley has failed to demonstrate that the trial court lacked jurisdiction to convict him or that his judgment of conviction was invalid on its face. Davis 2 v. State, 2025 Ark. 185, 722 S.W.3d 513.2 The circuit court did not clearly err when it denied and dismissed Marbley’s habeas petition. Affirmed. Special Justice CORY COX joins. WEBB, J., not participating. Jaster Lee Marbley, pro se appellant. Tim Griffin, Att’y Gen.; by: Vada Berger, Deputy Att’y Gen., for appellee. 2 Marbley was convicted of aggravated robbery in violation of Arkansas Statutes Annotated section 41–2102 (Supp. 1979). He committed it in 1982. Hudson, No. CR83- 112. At the time of his offense, aggravated robbery was a Class A felony, punishable by a term of imprisonment not less than five years nor more than fifty years, or life. Ark. Stat. Ann. § 41–901(1)(a) (Repl. 1977). 3