Jeffery Earl Matlock v. State of Arkansas
CourtCourt of Appeals of Arkansas
Date FiledSeptember 2, 2026
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
Cite as 2026 Ark. App. 387
ARKANSAS COURT OF APPEALS
DIVISION III
No. CR-25-296
JEFFERY EARL MATLOCK Opinion Delivered September 2, 2026
APPELLANT APPEAL FROM THE HOT SPRING
COUNTY CIRCUIT COURT
V. [NO. 30CR-22-75]
STATE OF ARKANSAS HONORABLE STEPHEN L. SHIRRON,
JUDGE
APPELLEE AFFIRMED
WAYMOND M. BROWN, Judge
Appellant Jeffery Matlock was found guilty by a Hot Spring County Circuit Court jury of
possession of a firearm by certain persons, second-degree domestic battery, and first-degree
terroristic threatening. He was sentenced to a twenty-nine-year term of incarceration in the Arkansas
Division of Correction.1 We affirmed his convictions on direct appeal. 2 Matlock now appeals the
1 Matlock was sentenced to serve consecutive terms of incarceration of seventeen years, six
years, and six years, respectively.
2 Matlock v. State, 2024 Ark. App. 69, 683 S.W.3d 621.
denial of his petition for postconviction relief filed pursuant to Arkansas Rule of Criminal Procedure
37.1.3 Because Matlock has failed to demonstrate that he is entitled to such relief, we affirm.4
On appeal from a circuit court’s ruling on a petitioner’s request for Rule 37 relief, this court
will not reverse the circuit court’s decision granting or denying postconviction relief unless it is
clearly erroneous.5 A finding is clearly erroneous when, although there is evidence to support it, the
appellate court after reviewing the entire evidence is left with the definite and firm conviction that a
mistake has been made.6
The benchmark for judging a claim of ineffective assistance of counsel is “whether counsel’s
conduct so undermined the proper functioning of the adversarial process that the trial cannot be
relied on as having produced a just result.”7 Pursuant to Strickland, we assess the effectiveness of
counsel under a two-prong standard. First, a petitioner raising a claim of ineffective assistance must
show that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed
the petitioner by the Sixth Amendment to the United States Constitution. 8 A petitioner making an
ineffective-assistance-of-counsel claim must show that counsel’s performance fell below an objective
3 (2023).
On May 20, 2025, Matlock’s counsel filed a motion seeking the recusal or disqualification
4
of Judge Stephanie Potter Barrett. The motion was passed to the panel for consideration with the
submission of the case. Because Judge Barrett is not on this panel, the motion is moot.
5 Kemp v. State, 347 Ark. 52, 60 S.W.3d 404 (2001).
6 Id.
7 Strickland v. Washington, 466 U.S. 668, 669 (1984).
8 Williams v. State, 369 Ark. 104, 251 S.W.3d 290 (2007).
2
standard of reasonableness.9 A court must indulge in a strong presumption that counsel’s conduct
falls within the wide range of reasonable professional assistance.10
Second, the petitioner must show that counsel’s deficient performance so prejudiced
petitioner’s defense that he or she was deprived of a fair trial.11 The petitioner must show there is a
reasonable probability that, but for counsel’s errors, the fact-finder would have had a reasonable
doubt respecting guilt, i.e., the decision reached would have been different absent the errors.12 A
reasonable probability is one that is sufficient to undermine confidence in the outcome of the trial.13
Unless a petitioner makes both showings, it cannot be said that the conviction resulted from a
breakdown in the adversarial process that renders the result unreliable.14 Additionally, conclusory
statements that counsel was ineffective cannot be the basis for postconviction relief.15
On appeal, Matlock first contends that his sentence for possession of a firearm by certain
persons is illegal because the jury was instructed on the elements supporting Class D felon in
possession, not the elements of Class B felon in possession for which he was sentenced.
9
Abernathy v. State, 2012 Ark. 59, 386 S.W.3d 477 (per curiam).
10 Id.
11 Id.
12 Howard v. State, 367 Ark. 18, 238 S.W.3d 24 (2006).
13 Id.
14 Id.
15 Anderson v. State, 2011 Ark. 488, 385 S.W.3d 783.
3
Arkansas Code Annotated section 5-73-103(c)(1)16 provides that possession of a firearm by
certain persons is a Class B felony if the person has a prior violent felony conviction. Matlock contends
that, at trial, he stipulated to the fact that he had a prior felony conviction, not a violent felony
conviction. He further asserts that the instructions to the jury stated, in part, that the State must
prove that he had been convicted of a felony. Matlock argues that “what the jury actually was asked
to find, and what it did find, was the Class D level of the offense.” He appears to argue that sentencing
him pursuant to the statutory range for the Class B level of the charged offense illegally increased the
penalty for the crime submitted to the jury and proved beyond a reasonable doubt. Thus, he asserts
that his Class B level conviction and sentence should be reduced to the Class D level of the offense.
Although Matlock attempts to craft his argument as one contesting an illegal sentence, it is
clearly a challenge to the conviction itself. A direct challenge to the sufficiency of the evidence is not
cognizable in postconviction proceedings.17
Furthermore, the record demonstrates that Matlock was charged by criminal information
with possession of a firearm by certain persons (or felon in possession) at the Class B felony level.
He was also convicted and sentenced at the Class B felony level. Notably, in the sentencing phase of
trial, the State introduced certified copies of Matlock’s extensive criminal history as a habitual
offender with eight prior felony convictions, including violent felonies such as aggravated robbery
and aggravated assault. The jury was instructed that Matlock’s conviction of possession of a firearm
by certain persons subjected him to a sentence ranging from not less than five years and not more
16 (Repl. 2024).
17 See Bell v. State, 2010 Ark. 65, 360 S.W.3d 98.
4
than forty years in the Arkansas Division of Correction. The jury returned a sentence of seventeen
years on the possession charge, well within the statutory sentencing range for a Class B felony.
To the extent that Matlock asserts that the jury instructions were inaccurate, such claims are
to be raised on direct appeal, although here, the argument would have been meritless. It is well
settled that no party may assign as error the giving of or failure to give an instruction unless he objects
thereto before or at the time the instruction is given, stating distinctly the matter to which he objects
and the grounds for his objection.18 Matlock failed to object to the jury instructions, only raising the
issue for the first time in his petition seeking postconviction relief.
Matlock also contends that his trial counsel and appellate counsel were ineffective for not
challenging the sufficiency of the evidence supporting his sentence at the Class B felony level. The
evidence introduced at trial established that Matlock has an extensive criminal history, with eight
prior felony convictions, including violent felony convictions. When a petitioner asserts that counsel
is ineffective for failing to make a motion or an argument, the petitioner must show that the motion
or argument would have been meritorious, because the failure to make an argument that is meritless
is not ineffective assistance of counsel.19 The circuit court did not err in denying postconviction relief
on this point.
Matlock next argues that his trial counsel’s performance fell below an objective standard of
reasonableness amounting to ineffective assistance for failure to seek severance of the felon-in-
possession-of-a-firearm charge. He specifically argues that “[b]ecause of the failure to sever, the jury
18 See Bridges v. State, 327 Ark. 392, 938 S.W.2d 561 (1997).
19 Duck v. State, 2020 Ark. App. 161, 596 S.W.3d 571.
5
found out that he was a convicted felon, although that was a highly prejudicial fact.” Pointing to the
victim, Carla Thompson’s repudiation of the allegations against him, Matlock argues that he was
entitled to severance “because the other evidence was weak.”
At the evidentiary hearing on the postconviction petition, Matlock’s trial counsel, Joseph
Jackson, testified that he discussed severance with Matlock, and per his recollection, Matlock agreed
to not seek severance and that he wanted only one trial because he did not want to “give the State
two different shots at the apple to have him convicted[.]” Trial strategy and tactics are not a basis for
postconviction relief.20 When a decision by counsel was a matter of trial strategy, and that decision
is supported by reasonable professional judgment, postconviction relief under Rule 37 is not available
even when the chosen strategy was improvident in retrospect. 21 Moreover, Matlock has failed to
demonstrate how the outcome of the trial would have been different if the possession-of-a-firearm-
by-certain-persons charge had been severed. Matlock also argues that his trial counsel provided
ineffective assistance by not requesting jury instructions on lesser-included offenses for the charges
of second-degree domestic battering and first-degree terroristic threatening. He contends that “it is
likely that the jury convicted [him] of the felonies because the lesser charges were not available to
them.” Matlock further asserts that his acquittal of two related charges—kidnapping and aggravated
assault of a family or household member—demonstrates prejudice. However, he fails to provide
facts or evidence in support of that allegation. The burden is entirely on the claimant to provide facts
that affirmatively support his or her claims of prejudice; neither conclusory statements nor allegations
20 State v. Barrett, 371 Ark. 91, 263 S.W.3d 542 (2007).
21 Lee v. State, 2017 Ark. 337, 532 S.W.3d 43.
6
without factual substantiation are sufficient to overcome the presumption that counsel was effective,
and such general statements and allegations will not warrant granting postconviction relief. 22
In light of the foregoing, we hold that the circuit court did not clearly err in denying Matlock’s
Rule 37.1 petition.
Affirmed.
VIRDEN and WOOD, JJ., agree.
Jeff Rosenzweig, for appellant.
Tim Griffin, Att’y Gen., by: Michael Zangari, Ass’t Att’y Gen., for appellee.
22 Abernathy v. State, 2012 Ark. 59, 386 S.W.3d 477.
7