Justia Arkansas Supreme Court Opinion Summaries

Appellant, a parolee, was charged as a habitual criminal offender with simultaneous possession of drugs and a firearm, possession of methamphetamine with intent to deliver, and possession of drug paraphernalia. Appellant filed a motion to suppress the evidence seized during his arrest on the basis that officers entered his hotel room without a warrant and without knocking and announcing their presence. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the knock-and-announce rule applies to parolees, but the exclusionary rule is not the appropriate remedy; and (2) despite the knock-and-announce violation, the evidence seized from Appellant should not have been suppressed. View "Lane v. State" on Justia Law

Defendant pleaded guilty to charges from several different cases, including first-degree murder, aggravated robbery, and first-degree escape. Defendant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due to his counsel’s failure to request a competency hearing. The circuit court denied relief, concluding that trial counsel made a reasonable decision not to pursue the competency question further, and that decision did not prejudice Defendant. The Supreme Court affirmed, holding that Defendant did not satisfy the Strickland v. Washington test for ineffective-assistance-of-counsel claims under Rule 37.1. View "Beverage v. State" on Justia Law

After a jury trial, Appellant was found guilty of manslaughter. Appellant was sentenced to ten years’ imprisonment. The Supreme Court affirmed in part and reversed and remanded in part for a new trial, holding that the circuit court (1) did not err by excluding testimony about the victim’s character and previous acts of violence; (2) prejudicially erred by refusing to declare a mistrial when it was discovered that the court’s bailiff had barred members of Appellant’s family from the courtroom during voir dire; and (3) did not abuse its discretion by refusing to give instructions on negligent homicide and imperfect self-defense. View "Schnarr v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and first-degree battery. Defendant was sentenced to an aggregate sentence of sixty-five years’ imprisonment. The court of appeals affirmed. Thereafter, Defendant filed a petition for postconviction relief pursuant to Ark. R. Civ. P. 37.1, in which he asserted numerous claims of ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that the circuit court did not err in denying Defendant’s claims that his appellate counsel provided ineffective assistance and that his trial counsel provided ineffective assistance. View "Liggins v. State" on Justia Law

Appellees, three married female couples, filed suit against Appellant, the director of the Arkansas Department of Health, seeking a declaration that the refusal to issue birth certificates with the names of both spouses of the birth certificates of their respective minor children violated their equal protection and due process rights. Appellees also sought an order requiring Appellant to issue corrected birth certificates. The circuit court ordered Appellant to issue three amended birth certificates naming both spouses. The Supreme Court reversed, holding (1) the circuit court erred in finding that the case was controlled by Smith v. Wright; and (2) the circuit court erred in finding that Ark. Code Ann. 20-18-401(e) and (f) and Ark. Code Ann. 20-18-406(a)(2) facially violated Appellees’ rights to due process and equal protection. View "Smith v. Pavan" on Justia Law

Appellant was found guilty of aggravated robbery and theft of property with a firearm enhancement. Appellant was sentenced to life imprisonment. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that he was denied effective assistance of counsel and that he was denied a fair and impartial trial because the jury and victims were all white and the trial judge was aggravated with him. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court’s decision to deny the requested relief was not clearly erroneous. View "Turner v. State" on Justia Law

In 2013, Appellant was convicted of raping a young girl and sentenced to forty years’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The trial court denied relief, concluding that counsel’s performance was not ineffective. The Supreme Court affirmed, holding that the circuit court did not err in finding (1) counsel was not ineffective for failing to object to hearsay testimony from witnesses; (2) counsel was not ineffective for failing to object to a sleeping juror; and (3) counsel was not ineffective for failing to call into question the credibility of the alleged victims. View "Smith v. State" on Justia Law

After a jury trial, Defendant was found guilty of capital murder, two counts of aggravated robbery, and two counts of kidnapping. Defendant elected to forgo sentencing by the jury. The State did not seek the death penalty for the capital murder conviction, for which Defendant automatically received a life sentence without parole. The circuit court sentenced Defendant as a habitual offender to concurrent terms of life imprisonment for the remaining offenses. The Supreme Court affirmed, holding that, by making certain rulings, the circuit court did not deny Defendant (1) the right to self-representation, (2) the right of confrontation, or (3) the right to the assistance of counsel. View "Dennis v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts of computer exploitation of a child in the first degree and of twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The Supreme Court affirmed. Thereafter, Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied relief. Appellant appealed and filed a pro se motion for extension of time to file brief, motion for certified copies of records, and motion to use twelve-point typeface. The Supreme Court dismissed the appeal and declared the motions filed in relation to the appeal moot, holding that Appellant failed to establish that either trial counsel or appellate counsel was ineffective. View "Rea v. State" on Justia Law

In 2012, the Arkansas State Police conducted a sobriety checkpoint on an exit ramp on an interstate. Appellant was stopped and subsequently arrested and charged with driving while intoxicated. After a bench trial, Appellant was convicted of driving while intoxicated. Appellant appealed, arguing, inter alia, that the sobriety checkpoint was illegally conducted, requiring reversal of his convictions under the Fourth Amendment. The Supreme Court reversed, holding (1) the sobriety checkpoint was unconstitutional because the State failed to demonstrate that the field officers’ discretion was properly limited; and (2) the seizure of Appellant through the checkpoint stop was unreasonable, and therefore, any evidence obtained as a result of the checkpoint should have been suppressed. View "Whalen v. State" on Justia Law