Full Opinion

Cite as 2026 Ark. 153 SUPREME COURT OF ARKANSAS No. CV-26-272 Opinion Delivered: October 15, 2026 ANDREW ROSS, JR. APPELLANT PRO SE APPEAL FROM THE LINCOLN COUNTY CIRCUIT COURT; MOTION TO ADD V. EXHIBITS TO REPLY BRIEF [NO. 40CV-26-13] DEXTER PAYNE, DIRECTOR, ARKANSAS DIVISION OF HONORABLE JODI RAINES CORRECTION DENNIS, JUDGE APPELLEE AFFIRMED; MOTION MOOT. CODY HILAND, Associate Justice Appellant Andrew Ross, Jr., appeals from the denial and dismissal of his petition for writ of habeas corpus filed pursuant to Arkansas Code Annotated section 16-112-101 (Repl. 2016) in Lincoln County, where he is incarcerated. Ross alleged in his petition that the circuit court did not have jurisdiction to convict him because the arrest warrant was invalid due to a defective probable-cause affidavit. The circuit court denied and dismissed the petition, concluding that Ross’s claim should have been raised at trial and on direct appeal or in a timely petition filed pursuant to Arkansas Rule of Criminal Procedure 37.1. We affirm. Thus, Ross’s motion to add exhibits to his reply brief is moot. A Mississippi County jury convicted Ross of capital murder and sentenced him to life imprisonment for his participation in the robbery of a liquor store and the murder of its owner. Ross appealed, and this court affirmed. See Ross v. State, 346 Ark. 225, 57 S.W.3d 152 (2001). The circuit court’s ruling in a habeas proceeding will be upheld unless it is clearly erroneous. Davis v. State, 2025 Ark. 185, at 2, 722 S.W.3d 513, 515. A decision is clearly erroneous when the appellate court, after reviewing all the evidence, is left with the firm conviction that a mistake has been made. Id., 722 S.W.3d at 515. A petitioner for the writ who does not allege his or her actual innocence pursuant to Act 1780 of 2001 must plead either the facial invalidity of the judgment or the circuit court’s lack of jurisdiction and make a showing, by affidavit or other evidence, of probable cause to believe that he is being illegally detained. Id. at 2–3, 722 S.W.3d at 515. 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. at 3, 722 S.W.3d at 515. Unless the petitioner can show that the circuit court lacked jurisdiction or that the commitment order was invalid on its face, there is no basis for finding that a writ of habeas corpus should issue. Id., 722 S.W.3d at 515. A circuit court has subject-matter jurisdiction to hear and determine cases involving violations of criminal statutes and has personal jurisdiction over offenses committed within the county over which it presides. Crockett v. Payne, 2026 Ark. 62, at 2–3. As stated above, Ross alleged that the circuit court lacked jurisdiction due to a defective arrest warrant that was allegedly issued without probable cause. Allegations of an invalid arrest warrant do not constitute grounds for habeas relief. Cullen v. State, 2024 Ark. 60, at 6, 687 S.W.3d 114, 119. Ross incorrectly attempts to connect the circuit court’s jurisdiction to the validity of his arrest. Jurisdiction is the circuit court’s authority to hear and decide the case. Harkuf v. Kelley, 2021 Ark. 107, at 2, 622 S.W.3d 638, 640. Circuit 2 courts in Arkansas have subject-matter jurisdiction to hear and decide cases involving violations of Arkansas criminal statutes, and personal jurisdiction over offenders who have committed said violations within the county over which it presides. Harris v. Gass, 2024 Ark. 78, at 3, 687 S.W.3d 794, 797. On appeal, Ross challenges habeas proceedings in general and argues that the remedy is too narrow. We have repeatedly rejected such arguments and have made clear that one is held without lawful authority and thus entitled to a writ of habeas corpus when it is shown that the commitment order is invalid on its face or the circuit court lacked jurisdiction. Wallace v. Willock, 301 Ark. 69, 71, 781 S.W.2d 484, 485 (1989). Ross did not allege that his judgment of conviction for capital murder was illegal on its face and failed to demonstrate that the circuit court lacked subject-matter jurisdiction to convict him. Thus, the circuit court did not clearly err when it denied Ross’s petition for the writ. Affirmed; motion moot. Special Justice CORY COX joins. WEBB, J., not participating. Andrew Ross, Jr., pro se appellant. Tim Griffin, Att’y Gen., by: Christopher R. Warthen, Ass’t Att’y Gen., for appellee. 3