Lawrance Mahomes v. State of Arkansas
CourtCourt of Appeals of Arkansas
Date FiledSeptember 16, 2026
StatusPublished
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Full Opinion
Cite as 2026 Ark. App. 414
ARKANSAS COURT OF APPEALS
DIVISION II
No. CR-25-735
LAWRANCE MAHOMES Opinion Delivered September 16, 2026
APPELLANT
APPEAL FROM THE CONWAY
COUNTY CIRCUIT COURT
V. [NO. 15CR-20-44]
STATE OF ARKANSAS HONORABLE JERRY DON RAMEY,
APPELLEE JUDGE
REVERSED AND REMANDED FOR
RESENTENCING
WENDY SCHOLTENS WOOD, Judge
Lawrance Mahomes appeals a Conway County Circuit Court sentencing order
revoking his probation and sentencing him to eighty-four months’ imprisonment. On
appeal, Mahomes contends that his underlying probationary sentence was illegal because
he was not eligible for probation as a habitual offender; therefore, his case must be
remanded for resentencing. We agree and reverse and remand for resentencing. 1
On May 6, 2020, Mahomes pled guilty to failure to appear and was sentenced to
sixty months’ probation. Ark. Code Ann. § 5-54-120 (Repl. 2024). The sentencing order
reflects that Mahomes was sentenced as a habitual offender under Arkansas Code
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See Mahomes v. State, 2026 Ark. App. 92 (reversing and remanding for resentencing,
finding merit to the identical argument in companion case).
Annotated section 5-4-501(a) (Supp. 2025). On November 3, 2022, the State filed a
petition to revoke Mahomes’s probation, and the court entered a sentencing order
revoking it on February 14, 2024, as amended on March 28, 2024. The court sentenced
him as a habitual offender to eighty-four months’ imprisonment. Mahomes filed this
appeal.
Mahomes contends that his May 6, 2020 probationary sentence was illegal because
he was not eligible for probation as a habitual offender. Consequently, the court had no
authority to subsequently revoke the probationary sentence and sentence him to eighty-
four months’ imprisonment. He contends that his case must be remanded for
resentencing. The State concedes the error and agrees.
Sentencing in Arkansas is entirely a matter of statute, and no sentence shall be
imposed other than as prescribed by statute. Hewitt v. State, 2020 Ark. App. 172, at 2, 598
S.W.3d 531, 532. A sentence is void or illegal when the circuit court lacks authority to
impose it. Id., 598 S.W.3d at 532. Stated another way, when the law does not authorize the
particular sentence pronounced by the circuit court, the sentence is unauthorized and
illegal. Id. at 2–3, 598 S.W.3d at 532.
Arkansas law prohibits a circuit court from placing a defendant on probation if the
defendant has been previously convicted of two or more felonies in accordance with the
habitual-offender statute. Ark. Code Ann. § 5-4-301(a)(2)(B) (Supp. 2025). In the
underlying conviction for which Mahomes was sentenced to probation, Mahomes was
sentenced as a habitual offender under Arkansas Code Annotated section 5-4-501(a).
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Therefore, Mahomes’s underlying probation sentence violated section 5-4-301(a)(2) and is
illegal. See, e.g., Mahomes, 2026 Ark. App. 92, at 3–4; Hewitt, 2020 Ark. App. 172, at 3–4,
598 S.W.3d at 531.
Accordingly, we reverse and dismiss the probation-revocation proceeding and
remand to the circuit court to sentence Mahomes within the statutory range as a habitual
offender for his underlying failure-to-appear conviction.
Reversed and remanded for resentencing.
TUCKER and HIXSON, JJ., agree.
Robert M. “Robby” Golden, for appellant.
Tim Griffin, Att’y Gen., by: A. Evangeline Bacon, Ass’t Att’y Gen., for appellee.
3