Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellant was convicted of second-degree murder and sentenced to 300 months' imprisonment with a firearm enhancement of 180 months. In his habeas petition, Appellant alleged that the judgment of conviction did not reflect that his sentence was enhanced as a habitual offender by requiring him to serve 100 percent of his sentence, and therefore, his sentence was illegal. The circuit court denied the petition. The Supreme Court affirmed, holding that because the judgment may be corrected at any time to reflect that Appellant was not eligible for parole, Appellant failed to demonstrate that he was entitled to habeas relief on the basis that his enhanced sentence was illegal. View "Jones v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without the possibility of parole, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the conviction; (2) the circuit court did not err in admitting evidence regarding Defendant's prior bad acts under Ark. R. Crim. P. 404(b) because the evidence had independent relevance and was not unduly prejudicial; and (3) the circuit court did not err in not allowing Defendant to question a detective regarding a prior inconsistent statement made by a witness. View "Atwood v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant did not state a ground for the writ.Appellant was found guilty of first-degree murder and sentenced as a habitual offender to 600 months' imprisonment. Appellant later filed a petition for writ of habeas corpus, asserting that the judgment was void because the information was signed by a deputy prosecutor rather than the prosecuting attorney. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant did not establish a basis for the writ because Appellant's claim was not cognizable in habeas proceedings. View "Sims v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of three counts of rape, holding that there was no prejudicial error in the proceedings below.After a jury trial, Defendant was convicted of three counts of rape and sentenced to life imprisonment on each count. The Supreme Court affirmed, holding (1) the circuit court did not err when it did not grant Defendant's motion for a directed verdict; and (2) Defendant was not prejudiced and his right to a fair trial was not put in jeopardy when the circuit court allowed one of the victims to remain in the courtroom throughout the trial. View "Dominguez v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se motion to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that the motion was untimely.In 1990, Defendant was convicted of burglary and theft of property. Defendant was sentenced to forty years' imprisonment and thirty years' imprisonment, respectively. In his motion to correct an illegal sentence, Defendant argued that making the thirty-year sentence part consecutive and part concurrent was illegal. The trial court denied relief. The Supreme Court affirmed, holding (1) although Defendant characterized his claim as one alleging a facially invalid sentence, it was not, and therefore, section 16-90-111 did not apply; and (2) under Ark. R. Crim. P. 37.2(c), Defendant's motion was untimely. View "Prince v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed Appellant's appeal from the circuit court's denial of Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that this Court lacked jurisdiction over the appeal.Appellant was convicted of capital murder and first-degree battery and sentenced to life imprisonment without parole. Appellant later filed a petition to correct an illegal sentence. The circuit court denied the petition, finding that it was untimely under Ark. R. Crim. P. 37.2. Appellant appealed. The Supreme Court affirmed, holding that Appellant did not proceed in the proper circuit court, and thus, the circuit court and the Supreme Court lacked jurisdiction to address his petition. View "Grant v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court granted in part and dismissed in part an original action brought by Petitioners challenging the sufficiency of a state-wide petition to refer Act 579 of 2019 to the people of Arkansas on the November 3, 2020 general election ballot, holding that the petition was insufficient because it did not comply with Ark. Code Ann. 7-9-601(b)(3).Act 579 expanded the scope of the practice of optometry in Arkansas to permit licensed optometrists to perform certain procedures. Safe Surgery Arkansas (SSA), a ballot-question committee, filed with the Secretary its petition containing more than 84,000 signatures. The Secretary certified that the petition met constitutional signature requirements. Thereafter, Petitioners filed the instant original action alleging four counts regarding the insufficiency of the petition. The special master found that SSA lacked sufficient valid signatures to qualify the petition for the ballot. The Supreme Court granted in part and dismissed as moot in part the petition, holding (1) SSA's petition was insufficient because it failed to certify that its paid canvassers had passed criminal background checks; and (2) the remaining challenges to the petition were moot. View "Arkansans for Healthy Eyes v. Thurston" on Justia Law

Posted in: Election Law
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The Supreme Court dismissed as moot Count I of Petitioners' complaint alleging that a proposed ballot petition's ballot title and popular name were invalid, holding that, in light of the holding of a companion case handed down today concluding that the proposed ballot petition was insufficient, Count I was moot.The Secretary of State certified a statewide referendum petition on Act 579 of 2019 for placement on the November 3, 2020 general-election ballot. Petitioners filed this original action challenging the proposed ballot petition and alleging four counts related to the sufficient of the petition. The Supreme Court bifurcated the proceedings between Count I and Counts II-IV. In a companion case, the Supreme Court granted the petition in part, concluding that the proposed ballot petition was insufficient. Because of this holding, any rulings on the issues in Count I were moot. View "Arkansans For Healthy Eyes v. Thurston" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the judgment of the trial court denying and dismissing Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to issue the writ.Appellant pleaded guilty to robbery and first-degree battery. Appellant later filed a petition for a writ of error coram nobis, asserting that his attorney and the prosecutor conducted a scheme to deceive him into entering a guilty plea. The trial court denied relief. The Supreme Court affirmed, holding that Appellant's conclusory claims in support of the allegation were not a ground for the writ and that Appellant did not meet his burden of establishing that the plea was the result of fear, duress, or threats of mob violence. View "Addison v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court denying Defendant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying relief.Defendant pleaded guilty to sexual abuse and was sentenced to 360 months' imprisonment. Defendant later filed a petition for a writ of error coram nobis alleging that the prosecutor withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that there is a reasonable probability that the judgment of conviction would not have been rendered or would have been prevented had the allegedly withheld information been disclosed; and (2) the circuit court did not err by not conducting an evidentiary hearing on the petition. View "Wood v. State" on Justia Law

Posted in: Criminal Law