Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of four counts of sexual assault of a fourteen-year-old boy. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming dissatisfaction with the trial judge, trial error, and ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted Appellant’s motion for extension of time to file his brief-in-chief, holding (1) the allegations concerning the judge’s conduct did not rise to a showing of fundamental error sufficient to void the judgment; (2) Appellant failed to establish that his attorney was ineffective; and (3) Appellant did not establish that any claim of trial error raised in the petition was sufficient to void the judgment in his case. View "Nelson v. State" on Justia Law

Nationwide Mutual Fire Insurance Company issued a policy to Danny Ludwick insuring his home and its contents. The policy named Citizens Bank & Trust Company as the first mortgagee. The dwelling was subsequently destroyed by fire. However, based on material misrepresentations in Ludwick's application, Nationwide voided the policy back to its inception. Citizens submitted a claim to Nationwide. Nationwide denied the claim on the basis that the policy was void ab initio, allegedly extinguishing not only Ludwick’s interest but also Citizen’s interest as mortgagee. Citizens filed a complaint for wrongful denial of its claim. The circuit court granted summary judgment to Citizens. The Supreme Court affirmed, holding (1) an insurance company is entitled to rescission of its insured’s policy based on the insured’s fraud or misrepresentation, but the rescission of the policy has no effect on an independent contract with the mortgagee; and (2) because the policy at issue contained a standard mortgage cause, which operated as an independent contract between the insurance company and the named mortgagee, the rescission of Nationwide’s policy had no effect on the independent contract with Citizens. View "Nationwide Mut. Ins. Co. v. Citizensbank & Trust Co." on Justia Law

In 1986, Petitioner was found guilty of three felony offenses for which the circuit court imposed an aggregate sentence of life imprisonment. The Supreme Court affirmed. In 2013, Petitioner filed a pro se petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court held that none of Petitioner’s claims was sufficient to void the judgment-and-commitment order and denied the petition. Petitioner subsequently filed a second Rule 37.1 petition, alleging several claims of error that were raised in his original Rule 37.1 petition. The Supreme Court dismissed the petition, holding that Petitioner did not raise a claim sufficient to void the judgment in his case. View "Munnerlyn v. State" on Justia Law

After a jury trial, Appellant was found guilty of murder in the second degree and sentenced as a habitual offender to 540 months’ imprisonment. Appellant subsequently filed a petition for postconviction relief seeking to vacate the judgment. Appellant’s signature on the petition was notarized, but the petition was not verified in accordance with Ark. R. Crim. P. 37.1(c). After a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that because Appellant’s petition was not in compliance with Rule 37.1(c), it did not act to confer jurisdiction on the trial court to consider the merits of the petition. View "Mason v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder, for which he was sentenced to a term of life imprisonment without the possibility of parole, and other offenses. On appeal, Appellant argued that the circuit court erred by not allowing him to cross-examine his codefendant about her prior misdemeanor third-degree domestic battery conviction for having stabbed Appellant. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in excluding the evidence, as (1) the testimony had very little probative value relating to the codefendant’s alleged bias against Appellant; (2) Appellant failed to establish that the evidence was proper modus operandi evidence; and (3) Appellant failed to put forth evidence to make a defense that the codefendant was the person who stabbed the victim. View "Lewis v. State" on Justia Law

Appellee, who was seventeen years old at the time of the offenses, pled nolo contedere to committing several crimes, including kidnapping. The circuit court sentenced Appellee to life imprisonment for his kidnapping conviction. The U.S. Supreme Court subsequently issued its decision in Graham v. Florida, holding that the Eighth Amendment forbids a sentence of life without parole for a juvenile offender who did not commit homicide. Appellee subsequently filed a writ of habeas corpus alleging that, pursuant to Graham, his life sentence was unconstitutional. After a sentencing hearing, the circuit court sentenced Appellee to a term of forty years’ imprisonment for the kidnapping conviction. The State appealed, arguing that the circuit court erred in not sentencing Appellee to a term of life imprisonment with the possibility of parole. Appellee cross-appealed. The Supreme Court affirmed, holding (1) the circuit court correctly ruled that the maximum sentence available after invalidation of Appellee’s life sentence was forty years; and (2) Graham did not entitle Appellee to additional consideration of his youth or the circumstances of his crime to reduce his sentence even further. View "Hobbs v. Turner" on Justia Law

After a jury trial, Appellant was found guilty of possession of a controlled substance with intent to deliver. Appellant later filed a pro se petition for writ of habeas corpus, contending (1) he was subjected to an illegal search and seizure of evidence and an illegal arrest, and (2) insufficient evidence supported the judgment as revealed in contradictory testimony of witnesses at trial. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared moot the motion filed in relation to the appeal, holding that Appellant failed to raise a claim within the purview of a habeas action and thus failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Green v. State" on Justia Law

After a jury trial, Appellant was found guilty of domestic battery in the first degree. Appellant subsequently filed a pro se petition for postconviction relief, which the trial court denied without a hearing. The Supreme Court affirmed the denial, holding (1) the trial court did not err by not appointing an attorney to represent Appellant on his postconviction petition; (2) Appellant’s challenge to his sentence was not cognizable in a postconviction proceeding; and (3) the trial court did not err in holding that Appellant’s counsel did not provide ineffective assistance under the standard set forth in Strickland v. Washington. View "Ellis v. State" on Justia Law

Petitioner was found guilty of kidnapping and sentenced to 240 months’ imprisonment. The court of appeals affirmed. Petitioner subsequently filed a petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he could proceed with a petition for writ of error coram nobis, alleging that he was returned to prison on a case that had been dismissed in 1996. The Supreme Court denied the petition, holding that Petitioner was not entitled to relief because his claim did not fit any of the categories within the purview of a coram nobis proceeding. View "Zulpo v. State" on Justia Law

Defendant entered a conditional guilty plea to trafficking a controlled substance. The court of appeals affirmed. Defendant subsequently filed a petition for review, arguing that the circuit court erred in failing to suppress evidence seized during a traffic stop of the rental cae Defendant was driving because the law enforcement’s placement of a GPS tracking device on the vehicle without a warrant and gathering data about the vehicle’s movements was an unconstitutional search under United States v. Jones. The Supreme Court affirmed without considering Defendant’s argument that planting the GPS device was an unreasonable search under Jones, holding (1) Defendant had no legitimate expectation of privacy in the vehicle and no standing to challenge the search of the rental car; and (2) although Defendant had standing to challenge his own detention, the detention was reasonable. View "Wilson v. State" on Justia Law