On October 22, 2025, the Arkansas Court of Appeals overturned a decision by the Carroll County Circuit Court that had dismissed Jediah Ryan Haley’s appeal of a third-degree battery conviction. The appellate court found that the circuit court erred in dismissing the appeal based on a technicality related to the filing process.
The Core Issue: A Technicality in the Filing Process
The central issue in this case revolved around Arkansas Rule of Criminal Procedure 36(c). This rule outlines the steps required to appeal a decision from a district court to a circuit court. One of the requirements is that the appellant (Haley, in this case) must:
* File a written request with the district court clerk asking for the record of the case to be prepared.
* Serve a copy of that written request on the prosecuting attorney for the judicial district.
* File a certificate with the district court clerk confirming that the written request was served.
Haley did file the certified record with the circuit court and paid the required fees. However, the State argued that Haley failed to serve the State with a copy of the written request for the record and failed to file a certificate of service. The State argued that these omissions were fatal to Haley’s appeal, and the circuit court agreed, dismissing the case.
The Court of Appeals’ Reasoning: Focusing on the Substance of the Appeal
The Court of Appeals disagreed with the circuit court’s decision, citing a previous ruling, *Pettry v. State*, from 2020. The *Pettry* case established that the filing of the certified record in the circuit court within the required timeframe is what gives the court jurisdiction over the appeal. The other requirements of Rule 36(c), such as serving the written request, are considered administrative, not jurisdictional.
The Court of Appeals emphasized that the focus should be on the substance of the appeal, not on minor procedural errors. The court noted that the State was aware of the appeal and was, in fact, present at the hearings. The court also pointed out that the circuit clerk is required to notify the State of any appeal, so the State was not prejudiced by Haley’s failure to serve the written request.
The Court of Appeals also referenced a subsequent ruling, *State v. Van Voast* (2022), which further supported the idea that the written notice to the prosecutor was not necessary to perfect the appeal.
The Ruling: Appeal Reinstated
Based on the precedents set in *Pettry* and *Van Voast*, the Court of Appeals reversed the circuit court’s decision and sent the case back to the circuit court for further proceedings. This means that Haley’s appeal of his battery conviction will now move forward.
The court’s decision highlights a trend away from strict adherence to technical procedural rules and a greater focus on ensuring that defendants have their cases heard on their merits.