Justia Arkansas Supreme Court Opinion Summaries

Appellant pleaded guilty to second-degree sexual assault Appellant and was required to register as a sex offender. The Arkansas Department of Correction Sex Offender Screening & Risk Assessment Program (SOSRA) assigned Appellant a Community Notification Level 3 after conducting a community notification risk assessment. The Sex Offender Assessment Committee upheld the Level 3 assessment. The circuit court denied and dismissed Appellant's petition for judicial review of the final administrative order. Appellant appealed the denial of his petition, and the Committee filed a cross-appeal of the denial of its motion to dismiss for lack of jurisdiction based on an untimely petition. The Supreme Court reversed on cross-appeal, holding that Petitioner did not establish that the petition had been timely filed, and therefore, the motion to dismiss should have been granted. View "Edwards v. State" on Justia Law

In 2009, Appellant entered a plea of guilty to aggravated robbery and battery in the second degree. Appellant's probation for an earlier conviction for aggravated assault was also revoked. The circuit court imposed an aggregate sentence of 180 months' imprisonment. In 2013, Appellant filed a pro se petition to correct an illegal sentence, alleging that she was forced to sign a plea agreement by which she would be required to serve seventy percent of the sentence imposed and that, at the time, she believed she would be required to serve only fifty percent of the sentence. The trial court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that the petition was not timely filed as to the judgment-and-commitment order or the revocation order, and thus the trial court lacked jurisdiction to grant the requested relief. View "Ybarra v. State" on Justia Law

In 1998, after a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to an aggregate term of sixty-five years' imprisonment. The court of appeals affirmed. In 2010, Appellant filed a petition for writ of habeas corpus under Act 1780 of 2001 seeking scientific testing of certain evidence. The circuit court denied the petition, finding it to be untimely because the evidence was not newly discovered for purposes of the Act. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's petition on the ground that it was untimely filed because Appellant failed to rebut the presumption against timeliness; and (2) the remainder of Appellant's petition raised claims that were not cognizable in a petition for habeas corpus, and therefore, the circuit court's denial of Appellant's petition was not clearly erroneous. View "Turner v. State" on Justia Law

Appellant and her two uncles each owned as tenants in common an undivided one-third interest in two tracts of farmland. Both of Appellant's uncles separately sold their interest in the property to Appellee. Appellee subsequently sold one of the farms. Appellant filed a complaint seeking a partition of the lands and damages for breach of fiduciary duty as a tenant in common, tortious interference, and deceptive trade practices. Appellant claimed that Appellee prevented a family partnership from entering into seven-year renewal leases with farmers who leased the farmland and prevented the partnership from implementing a long-term plan for improving the farms. The circuit court granted summary judgment in Appellee's favor and dismissed the action with prejudice. The Supreme Court affirmed, holding that the circuit court properly granted summary judgment on Appellant's three claims, as Appellant failed to meet proof with proof that she sustained any damages as a result of Appellee's alleged breach of fiduciary duty, alleged tortious interference, and alleged deceptive trade practice. View "Skalla v. Canepari" on Justia Law

In 2008, Appellant entered a negotiated plea of guilty in the Carroll County Circuit Court to first-degree stalking, kidnapping, residential burglary, and misdemeanor theft of property. In 2012, Appellant filed in the Carroll County Circuit Court a pro se petition for writ of habeas corpus. The circuit court denied the petition. Appellant appealed and filed a motion to appoint counsel. The Supreme Court dismissed the appeal and declared the motion moot, holding that because Appellant was not incarcerated at a facility within Carroll County when he filed his petition, the circuit court lacked personal jurisdiction to effect Appellant's relief from custody. View "Meraz v. State" on Justia Law

Appellant pleaded guilty to sexual assault in the first degree and was sentenced to 660 months' imprisonment. Appellant later filed a two pro se petitions to correct a sentence illegal on its face and to reduce sentence, arguing that his sentence was illegal because he was not proven to be a habitual offender with four or more prior felony convictions who was subject to an enhanced sentence. The trial court denied both petitions. The Supreme Court affirmed, holding that the trial court's decision to deny Appellant's petitions was not clearly erroneous because the sentence Appellant received was within the statutory range for the offense. View "Grissom v. State" on Justia Law

Appellant pleaded guilty to one count of rape in the Perry County Circuit Court and one count of rape in the Conway County Circuit Court and was sentenced to a term of imprisonment. Appellant subsequently filed a petition for a writ of habeas corpus in Hot Spring County, where he was incarcerated, arguing that the Perry County Circuit Court lacked jurisdiction to convict and sentence him because the information pertaining to the investigation of the crime to which he pled guilty in Perry County indicated that the alleged sexual activity took place in Conway County. The circuit court denied the habeas petition. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Appellant failed to demonstrate probable cause that the Perry County Circuit Court lacked territorial jurisdiction to convict and sentence him on the rape charge; and (2) Appellant's claim that the Conway County judgment-and-commitment order was invalid on its face was not cognizable in this habeas corpus proceeding. View "Fields v. Hobbs" on Justia Law

Appellant was convicted of multiple counts of unlawful charge of a firearm from a vehicle and was sentenced to a term of imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001 (Act), alleging claims of (1) actual innocence; (2) failure of proof because a gun was not recovered; and (3) ineffective assistance of counsel, insufficient evidence, and due process violations. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that the claims raised by Appellant were not cognizable under the Act, and therefore, the trial court correctly determined that the relief Appellant sought fell outside the statute's scope. View "Clemmons v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder in furtherance of aggravated robbery and sentenced to a term of life imprisonment. The Supreme Court affirmed the judgment of the circuit court, holding (1) there was substantial evidence to support the jury's verdict; and (2) Appellant failed to establish that the circuit court erred when it refused to instruct the jury with a disputed-accomplice liability instruction, as, even if the circuit court's failure to instruct the jury on the disputed-accomplice liability was error, Appellant failed to demonstrate that he was prejudiced by the circuit court's failure to give the instruction. View "Wells v. State" on Justia Law

While an inmate in the Arkansas Department of Correction (ADC) East Arkansas Regional Unit (EARU), Appellant stabbed a correctional officer in the chest with a piece of fence wire. Consequently, Appellant was transferred to the Varner Supermax Unit (VSM) of the ADC and assigned to the VSM Incentive Level Program. Appellant subsequently filed a complaint pursuant to the Arkansas Civil Rights Act, alleging that his placement in the VSM Incentive Level Program violated his constitutional rights, including his rights to due process and equal protection. The trial court dismissed the complaint. The Supreme Court affirmed, holding that because Appellant failed to raise any legitimate constitutional issue in his petition, the trial court did not err in dismissing the complaint based on Petitioner's failure to state a claim for relief. View "Waller v. Banks" on Justia Law