Full Opinion

Cite as 2026 Ark. 118 SUPREME COURT OF ARKANSAS No. CR-25-494 Opinion Delivered: October 1, 2026 JAMES RHODES, JR. APPELLANT PRO SE APPEAL FROM THE DREW COUNTY CIRCUIT COURT V. [NO. 22CR-93-13] HONORABLE ROBERT B. GIBSON III, STATE OF ARKANSAS JUDGE APPELLEE AFFIRMED. COURTNEY RAE HUDSON, Associate Justice Appellant James Rhodes, Jr., was nineteen years old when he committed the offense of capital murder.1 He appeals from the denial of his petition to correct an illegal sentence filed pursuant to Arkansas Code Annotated section 16-90-111 (Repl. 2016). For reversal, Rhodes contends that the circuit court erred by not considering scientific data supporting the United States Supreme Court’s ruling in Miller v. Alabama, 567 U.S. 460 (2012), and finding that there is no substantial difference in the neurological brain development and maturity of young adults aged seventeen to twenty. Rhodes argues that, as a result of this data, his sentence of life imprisonment without parole is illegal. We affirm. 1 In 1993, Rhodes pleaded guilty and was sentenced to life imprisonment without parole. The sentencing order reflects that Rhodes was on probation for robbery and theft of property at the time of the murder. As a result of the probation violation, Rhodes was also sentenced to concurrent terms of twenty years’ and ten years’ imprisonment for the burglary and theft offenses. The trial court’s decision to deny relief pursuant to section 16-90-111 will not be overturned unless that decision is clearly erroneous. McGill v. State, 2025 Ark. 66. A finding is clearly erroneous when, although there is evidence to support it, the reviewing court on the entire evidence is left with the definite and firm conviction that a mistake has been made. Millsap v. State, 2020 Ark. 38. We are mindful that the plain text of Arkansas Code Annotated section 16-90-111(a) authorizes a trial court to correct an illegal sentence at any time. McGill, 2025 Ark. 66. An illegal sentence is one that is illegal on its face. Woodruff v. State, 2024 Ark. 13, 682 S.W.3d 662. A sentence is illegal on its face when it is void because it is beyond the trial court’s authority to impose and gives rise to a question of subject-matter jurisdiction. Id. The general rule is that a sentence imposed within the maximum term prescribed by law is not illegal on its face. Id. On appeal, Rhodes contends that the circuit court erred for the following reasons: (1) failing to consider scientific data to the effect that there is no substantial difference in young adults aged seventeen to twenty when it comes to neurological brain development and maturity; (2) failing to analyze “fellow sister states[’]” decisions concerning the neurological brain-development and maturity-level claims he made; and (3) failing to analyze decisions of the federal courts concerning his neurological-brain-development and maturity-level claims. Rhodes addresses two cases, People v. Taylor, ___ N.W.3d ___, 2025 WL 1085247 (Mich. 2 Apr. 10, 2025),2 and United States v. Sepulveda, 762 F. Supp. 3d 153 (D.R.I. 2025), for precedent to support his claim that a life sentence without parole for nineteen- and twenty- year-olds violates the benefit and protections of the specialized procedures mandated in Miller and that makes those in that age group presumptively neurologically indistinguishable from either a “teenage juvenile offender or an eighteen-year-old offender.”3 Although Rhodes argues that article 2, section 9, of the Arkansas Constitution mirrors Michigan’s clause prohibiting cruel or unusual punishment, which served as the basis to support the Michigan appellate court’s findings regarding its findings in Taylor, a claim based on a constitutional argument does not implicate the facial validity of the judgment. Therefore, such claims are not within the purview of the illegal-sentence statute. Mister v. State, 2022 Ark. 35, 639 S.W.3d 331; see Hogue v. State, 2026 Ark. 83, 732 S.W.3d 385. Rhodes contends that there are developments indicating a major change in how the law treats “emerging adults,” particularly because an “assessment of a punishment’s proportionality occurs ‘in light of contemporary standards of decency which mark the progress of society.’” Sepulveda, 762 F. Supp. 3d at 159 (citing Commonwealth v. Mattis, 224 N.E.3d 410 (2024) (internal citations omitted)). The United States Supreme Court in Miller held that a mandatory sentence of life without parole for a juvenile violates the Eighth 2 Rhodes also referenced People v. Czarnecki, 27 N.W.3d 634 (Mich. Ct. App. 2023), which was reversed by the holding in Taylor sub nomine. 3 Rhodes’s use of the term “teenage juvenile offender” likely refers to teenagers who are categorized as “juveniles” or “youths” as opposed to teenagers who are categorized as adults, i.e., eighteen- and nineteen-year-olds. 3 Amendment; the Court did not prohibit a juvenile from being sentenced to life without parole but required the sentencer to “take into account how children are different, and how those differences counsel against irrevocably sentencing them to a lifetime in prison.” Segerstrom v. State, 2024 Ark. 130, 696 S.W.3d 799 (quoting Miller, 567 U.S. at 480); see Grubbs v. State, 2020 Ark. 42, 592 S.W.3d 688. Again, this court has not extended its application of Miller to offenders who were eighteen or older at the time of the homicide. See Hogue, 2026 Ark. 83, 732 S.W.3d 385; Gibbs v. Payne, 2023 Ark. 29, 660 S.W.3d 579; see also Benton v. Kelley, 2020 Ark. 237, 602 S.W.3d 96. Moreover, Rhodes’s sentence is firmly within the statutory range for the offense of capital murder, and Rhodes does not argue otherwise. Rhodes was convicted of capital murder, a Class Y felony under Arkansas Code Annotated section 5-10-101 (Supp. 1992), punishable by death or life imprisonment without parole. Accordingly, Rhodes’s sentence of life without parole is within the range permitted by statute and is not facially illegal. Woodruff, 2024 Ark. 13, 682 S.W.3d 662. In light of the foregoing, we affirm the circuit court’s order because Rhodes failed to demonstrate that his sentence is illegal. Affirmed. Special Justice CORY COX joins. WEBB, J., not participating. James Rhodes, Jr., pro se appellant. Tim Griffin, Att’y Gen., by: Christopher R. Warthen, Ass’t Att’y Gen., for appellee. 4