Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of rape and second-degree assault and sentenced as a habitual offender to life imprisonment. Appellant subsequently filed a timely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 seeking to vacate the judgment. The circuit court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted his motion seeking a copy of the record on appeal, holding that because Appellant’s petition was not verified in accordance with Rule 37.1(c), the circuit court lacked jurisdiction to consider the merits of the petition. View "Stewart v. State" on Justia Law

Appellant pleaded guilty to kidnapping and third-degree domestic battery of a minor. The judgment-and-commitment order did not require that Appellant register as a sex offender, although the statutory scheme required Appellant to register based on his conviction. The trial court later entered a nunc pro tunc order requiring Appellant to register as a sex offender. Subsequently, the Arkansas Department of Correction Sex Offender Screening & Risk Assessment Program assigned Appellant a community notification risk assessment of Level 2. The Level 2 assessment was upheld on administrative review. Thereafter, Appellant filed a petition for judicial review. The circuit court dismissed the petition for lack of jurisdiction based on an untimely petition. The Supreme Court affirmed, holding that Appellant failed to establish that the petition had been timely filed, and accordingly, the circuit court did not err in dismissing the petition. View "Smith v. Ark. Dep't of Corr." on Justia Law

Petitioner, an inmate, filed a pro se petition for writ of habeas corpus. The circuit court granted the petition in part and denied it in part. Petitioner did not timely appeal and subsequently sought leave to proceed with a belated appeal. In support of his motion to proceed with his belated appeal, Petitioner contended that, as a functional illiterate, it was impossible for him to comply with procedural rules. The Supreme Court denied Petitioner’s motion to proceed with the appeal, holding that it was the duty of Petitioner to file a timely notice of appeal, and Petitioner did not establish good cause for his failure to do so. View "Sillivan v. Hobbs" on Justia Law

Appellant pled guilty to several drug-related charges and received five years of supervised probation. Appellant later pled that he had violated the conditions of probation. After a hearing, the circuit court sentenced Appellant to ten years incarceration. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief, asserting that his counsel was ineffective for (1) failing to raise the issue that the revocation hearing had been held outside the sixty-day limitation set by statute, and (2) not asserting that Appellant did not receive adequate notice of the alleged probation violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in its judgment. View "Johnson v. State" on Justia Law

Appellant pleaded guilty to first-degree murder and was sentenced to 480 months’ imprisonment. Appellant later filed a pro se petition for writ of error coram nobis alleging that his guilty plea was coerced and that he was incompetent at the time of entering the plea. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal and mooted his motion for extension of time to file his brief-in-chief, holding (1) Appellant’s allegation that his guilty plea was coerced due to ineffective assistance of counsel was outside the purview of a coram-nobis proceeding; and (2) the issue of Appellant’s competency could have been raised at the time his plea was entered and was not a ground for proceeding with a petition for writ of error coram nobis. View "Harris v. State" on Justia Law

Appellant, an inmate incarcerated under a sentence of life imprisonment without parole, filed a pro se petition for writ of habeas corpus alleging four bases for issuance of the writ, including the allegation that his commitment was invalid on its face because he had been charged with and pleaded guilty to murder in the first degree and had been sentenced for capital-felony murder. The circuit court dismissed Appellant’s petition without a hearing. The Supreme Court affirmed, holding (1) Appellant was charged with a capital felony, which was punishment by life imprisonment without parole; and (2) therefore, Appellant was sentenced correctly, his judgment of conviction was not illegal on its face, and habeas relief was not warranted. View "Gooch v. Hobbs" on Justia Law

Appellant pled guilty to sexual assault and was required to register as a sex offender. Appellant was assigned a community notification risk assessment Level 3. The Sex Offender Assessment Committee upheld the Level 3 assessment. Appellant subsequently petitioned for judicial review of the final administrative order. The circuit court denied the Committee’s motion to dismiss the appeal for lack of jurisdiction based on an untimely petition. The Supreme Court reversed, concluding that the circuit court did not have a basis to determine that the petition was timely because Appellant did not establish that he had complied with the rules of procedure so as to file a timely petition. Appellant subsequently filed a motion that the Supreme Court treated as a petition for rehearing. The Court then denied the motion, holding that Appellant failed to demonstrate any error of fact or law contained in the Court’s petition. View "Edwards v. State" on Justia Law

After a jury trial in 1989, Petitioner was found guilty of first-degree murder and sentenced as a habitual offender to life imprisonment. This appeal concerned the denial of Petitioner’s pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis. In his petition, Petitioner argued that the State withheld evidence during the trial proceedings in violation of Brady v. Maryland. Specifically, Petitioner argued that the State failed to disclose that criminal charges filed in Missouri, which were presented in support of Petitioner’s enhanced sentence as a habitual offender, were dismissed by the Missouri trial court while Petitioner’s appeal in the instant case was pending. The Supreme Court denied the petition, holding that, where twenty-three years had passed after the dismissal of the Missouri charges before Petitioner petitioned for relief, Petitioner’s failure to act with due diligence constituted good cause to deny the petition. View "Cherry v. State" on Justia Law

After a jury trial, Appellant was found guilty of possession of methamphetamine with intent to deliver and other drug-related offenses. After Appellant’s convictions were affirmed on appeal, Appellant unsuccessfully filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and, subsequently, a pro se petition for writ of habeas corpus. Appellant later filed a second pro se petition for writ of habeas corpus. The circuit court denied the petition. The Supreme Court affirmed, holding (1) to the extent Appellant argued that he was entitled to habeas relief because the trial court lacked jurisdiction and the authority to sentence him, this claim was barred by the law-of-the-case doctrine; (2) the law-of-the-case doctrine also applied to Appellant’s challenge to his consecutive sentences; and (3) Appellant’s request for jail-time credit was not cognizable in a petition for writ of habeas corpus. View "Bumgarner v. Hobbs" on Justia Law

After Decedent died, Decedent’s will was admitted to probate, and all of Decedent’s property was devised to his sister. Appellant petitioned to inherit from Decedent’s estate, claiming that she was the pretermitted child of Decedent and that she was entitled to receive all of his estate as his sole heir. The circuit court dismissed Appellant’s petition for failing to file her claim against the Estate and failing to establish her paternity within the 180-day period required under Ark. Code Ann. 28-9-209(d). The Supreme Court affirmed, holding that the circuit court did not err in dismissing Appellant’s petition due to her failure to satisfy the statutory requirements. View "Bell v. McDonald" on Justia Law