Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Arkansas Supreme Court
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After a trial, Petitioner was convicted of three felony offenses and sentenced to life imprisonment. Petitioner subsequently filed a petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court denied relief, holding (1) Petitioner's argument that the arrest warrant was invalid was not cognizable under Rule 37.1; (2) Petitioner's argument that the felony information was invalid was not a jurisdictional matter and was not sufficient to void the judgment; (3) Petitioner's argument that he was not adequately informed of his Miranda rights when he confessed was waived; and (4) Petitioner's allegations of ineffective assistance were not grounds for relief. View "Munnerlyn v. State" on Justia Law

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Appellant pled guilty to rape and first-degree sexual assault in 2003. In 2007 and 2011, Appellant filed three pro se petitions for writs of error coram nobis. In 2012, the circuit court denied the petitions in a single order. The Supreme Court dismissed Appellant's appeal and declared Appellant's petition for writ of certiorari to complete the appellate record moot, holding (1) because the 2007 petition was not included in the record, Appellant could not prevail as to those claims; (2) all claims in the 2011 petitions failed to allege a claim that would support error-coram-nobis relief; and (3) therefore, the trial court did not err in denying relief. View "Morgan v. State" on Justia Law

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Appellant pled guilty to aggravated robbery in 2009. In 2011, Appellant filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order was invalid because the trial court failed to comply with the Arkansas Rules of Criminal Procedure. The trial court denied the writ. Specifically, Appellant asserted that the trial court violated certain court rules with regard to the acceptance of guilty pleas at his plea hearing. The Supreme Court affirmed, holding that because Appellant failed to show that the judgment of conviction was facially invalid or that the circuit court lacked jurisdiction, the trial court properly declined to issue a writ of habeas corpus. View "McVane v. Hobbs" on Justia Law

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After a jury trial, Appellant was found guilty of aggravated robbery, aggravated assault, and theft of property and was sentenced to an aggregate term of 348 years' imprisonment. The Supreme Court affirmed. Appellant subsequently field a pro se petition for writ of habeas corpus, asserting that proper procedure was not followed when he was extradited to Arkansas after his arrest in Tennessee, and a sentence in excess of 300 years was outside the statutory range for the offenses of which he was convicted. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant failed to state a claim sufficient to warrant issuance of a writ of habeas corpus, and therefore, the circuit court did not err in declining to issue the writ. View "Malone v. Hobbs" on Justia Law

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After a trial, Appellant was convicted of murder in the first degree and battery in the third degree. Appellant's conviction was affirmed on appeal. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging that his due process rights were violated based on the constructive denial of counsel, judicial abuse of discretion, and prosecutorial misconduct. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because Appellant failed to show either that the judgment of conviction was invalid on its face or that the trial court lacked jurisdiction, the circuit court properly determined that the writ should not issue. View "Lewis v. State" on Justia Law

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After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment. More than two decades later, Appellant filed a pro se petition for writ of habeas corpus in the circuit court, alleging error in his trial. The circuit court dismissed the petition. On appeal, Appellant contended that an automatic sentence of life without parole is illegal on its face and a violation of the state and federal constitutional prohibition of ex post facto laws. The Supreme Court affirmed, holding that because Appellant's claims did not challenge the facial validity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Jones v. Hobbs" on Justia Law

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Tammye and Justin were divorced in 2010 by way of a consent divorce decree that included a property-settlement agreement. In 2011, Tammye filed a motion to increase child support, asserting that there had been a material increase in Justin's income, or alternatively, that the original child-support award had been based on figures fraudulently provided by Justin. Although the circuit court discovered assets hidden by Justin at the time of the original award, the court denied Tammye's motion. The Supreme Court affirmed, holding (1) the circuit court misstated the law when denying Tammye's motion, but the court's erroneous statement of the law was not the sole basis for the circuit court's denial of Tammye's motion; and (2) the circuit court did not err in denying the motion. View "Hall v. Hall" on Justia Law

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In 1984, Appellant was charged in drew County with rape. The trial was held in Ashley County. A jury found Appellant guilty, and the judgment-and-commitment order was entered in Drew County. Appellant challenged the sentencing court's jurisdiction on appeal. The Supreme Court affirmed with the modification that the judgment-and-commitment order be filed in Ashley County. In 1984, Appellant also pled guilty to three additional felony offenses, and in 2007, Appellant pled guilty to eight more felony offenses. In 2011, Appellant filed a petition for writ of habeas corpus, which the circuit court dismissed. The Supreme Court affirmed, holding (1) Appellant's contention that the change of venue from Drew to Ashley county rendered the judgment in that case void was barred by res judicata; and (2) the remainder of Appellant's claims were not grounds for habeas relief. View "Douglas v. Hobbs" on Justia Law

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Appellant pled guilty to two counts of rape in the Garland County Circuit Court. Appellant subsequently filed a pro se petition for writ of habeas corpus in the trial court in Garland County. At the time the petition was filed, Appellant was incarcerated at the Arkansas Department of Correction located in Hot Spring County. The trial court denied the petition. Appellant appealed and filed a motion to file a belated brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the Garland County Circuit Court did not have personal jurisdiction to issue a writ of habeas corpus where Appellant was not in custody within the court's jurisdiction. View "Cooper v. Hobbs" on Justia Law

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After a jury trial, Defendant was convicted of five counts of committing a terroristic act and one count of possession of a firearm by a felon. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging, among other things, that his counsel was ineffective. The trial court denied the petition. The Supreme Court affirmed, holding that counsel did not provide ineffective assistance for (1) deciding not to challenge the information; (2) not challenging the jury instructions or verdict forms that tracked the elements of the charged crimes; and (3) failing to make a sufficient motion for a directed verdict to preserve a sufficiency-of-evidence argument for appeal. View "Anderson v. State" on Justia Law