Background
Keaton Taylor pleaded guilty in May 2018 to first-degree murder and aggravated robbery for crimes committed in 2016, when he was sixteen. He received an aggregate twenty-five-year prison sentence followed by a thirty-year suspended imposition of sentence.
In January 2025, Taylor asked the Columbia County Circuit Court to waive the statutory requirement that he serve 70 percent of his prison term before parole eligibility. He asserted that he met the statutory conditions for a discretionary waiver because he was a juvenile, merely an accomplice, and committed the offenses after July 28, 1995. The circuit court dismissed the motion, concluding that it no longer had jurisdiction after sentencing him in 2018.
The Court’s Holding
The Arkansas Court of Appeals affirmed. A request to waive the 70 percent service requirement is a collateral attack on a judgment and is therefore treated as a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37.
Because Taylor pleaded guilty, Rule 37 required him to file such a petition within ninety days after entry of judgment. Taylor filed more than six years after the 2018 judgment, so his motion was untimely and the circuit court lacked jurisdiction to consider it. The court rejected Taylor’s effort to distinguish prior precedent based on a later statutory amendment, explaining that the prior case’s timeliness ruling independently controlled.
Key Takeaways
- A motion seeking waiver of Arkansas’s 70 percent parole-service requirement is governed by Rule 37 postconviction deadlines.
- For a guilty plea, a Rule 37 petition must be filed within ninety days of the judgment.
- An untimely waiver request deprives the circuit court of jurisdiction, regardless of whether the movant may otherwise satisfy the waiver criteria.
Why It Matters
The decision confirms that the statutory discretion to waive the 70 percent requirement for qualifying juvenile accomplices does not create an open-ended post-sentencing remedy. Counsel seeking that relief must comply with Rule 37’s jurisdictional filing deadline.