10 According to Halliday, the rationale behind the direction of the writ “lay in a personal relationship: that between the [sovereign] and his franchisee.” Halliday, Habeas Corpus: From England to Empire at 42. As a result, “[p]eople, not places, were the objects of the writ’s supervision.” Id. at 43. For example, at the Bocardo Prison in Oxford, built in the 11th or 12th century, the King of England authorized various government officers to imprison and release inmates. Id. Directing a habeas petition to the jailor, when another government official had legal custody over the prisoner, would result in failure for misdirection. Id. (citing case law from the early 1600s). 11 The Supreme Court of Arkansas recently reached the same conclusion. Hundley v. Hobbs, 456 SW 3d 755 (Ark 2015) (<HOLDING>). In reaching that conclusion, the court relied
holding that a petition for review is an adequate substitute for habeas corpus holding that district court must resolve all claims for relief premised on alleged constitutional violations which are raised in a petition for writ of habeas corpus whether habeas relief is granted or denied holding that a habeas corpus petitioner who did not raise an ineffective assistance claim in his first state habeas petition satisfied the cause prong of the cause and prejudice test when counsel on the first state habeas petition was also trial counsel whose performance was allegedly inadequate holding that arkansas inmate incarcerated in new jersey pursuant to the icc was entitled to petition for habeas corpus relief in arkansas and properly directed the petition against the director of the arkansas department of corrections holding that the pendency of a petitioners federal habeas corpus petition does not divest a trial court of jurisdiction to address a pcra petition