By Ray King

An Arkansas prison inmate being held at the Pine Bluff Unit failed to convince the Arkansas Supreme Court that his trial occurred after the time limit for a speedy trial, making the conviction invalid.

Darryl Talley, 31, was convicted of aggravated robbery, theft of property and using a firearm to commit the robbery after a trial in Pulaski County in 2016 and was sentenced to 168 months in prison. He was originally charged in 2011 but the conviction followed an amended criminal information that was filed in 2013.

He appealed that conviction, claiming the trial court improperly denied his request to represent himself but the Arkansas Court of Appeals turned down that appeal, saying “from the outset and continuing through the pendency of this case, (Talley) repeatedly displayed an intent to delay and frustrate the orderly and effective administration of justice. As early as his arrest in 2011, he claimed to be a ‘sovereign citizen’ and refused to provide any identifying information. For more than four years, and throughout the entire pretrial process, he manipulated his right to counsel and his right to self-representation in order to delay and obstruct the proceedings of the trial court.”

Talley then sought to claim his rights to a speedy trial were violated, a claim that Circuit Judge Jodi Raines Dennis denied and dismissed. He then appealed Dennis’ decision to the Supreme Court.

Writing for the high court, Associate Justice Shawn Womack said that although Talley claimed Dennis failed to recognize a speedy trial violation deprives the trial court of jurisdiction, that claim is not true.

“Allegations of speedy trial violations are assertions of trial error that do not implicate the facial validity of the judgment or the jurisdiction of the court,” Womack said in the ruling. “If there were errors at trial, those issues should have been raised at trial and on the record on direct appeal.
According to the Arkansas Department of Correction website, Talley will be eligible to apply for parole on June 27, 2025.