Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of second-degree battery and of being a felon in possession of a firearm. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court ultimately concluded that Appellant’s claims were not supported by the record. The Supreme Court affirmed, holding (1) the trial court did not clearly err when it denied Appellant’s petition without conducting an evidentiary hearing; and (2) the trial court did not clearly err in concluding that counsel did not provide ineffective assistance. View "Russell v. State" on Justia Law

Daniel Wren requested from The Arkansas State Police (ASP) unredacted access to certain accident reports under the Freedom of Information Act (FOIA). ASP contended that its policy of redacting personal information from accident reports was permitted under FOIA because disclosure is prohibited by the federal Driver’s Privacy Protection Act (DPPA). The circuit court ruled in favor of Wren and enjoined the policy of the ASP regarding redactions of accident reports. The Supreme Court Affirmed, holding that the DPPA does not prohibit disclosure of personal information in accident reports, which are public records within the meaning of FOIA. View "Ark. State Police v. Wren" on Justia Law

After a jury trial, Appellant was convicted of possession of methamphetamine, being a felon in possession of a firearm, and simultaneous possession of drugs and firearms. The court of appeals affirmed Appellant’s convictions and sentences. Appellant subsequently filed a timely postconviction petition alleging that the trial court was biased and that his two attorneys failed effectively to represent him. The trial court denied relief. The Supreme Court affirmed, holding (1) under Strickland v. Washington, Appellant failed to establish that he was prejudiced by his attorneys’ performance; and (2) the trial court did not err when it denied Appellant’s claim for postconviction relief without holding an evidentiary hearing. View "Stover v. State" on Justia Law

After a jury trial, Defendant was convicted of rape. Defendant was sentenced to ten years in prison. The court of appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief arguing that he received ineffective assistance of counsel because his defense counsel failed to object to testimony that allegedly bolstered the victim’s credibility. The circuit court denied Defendant’s claim, concluding that defense counsel’s failure to object was based on trial strategy and that his performance was not deficient. The Supreme Court affirmed, holding that the circuit court did not err in finding that counsel’s failure to object was based on trial strategy. View "Fukunaga v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of rape. Appellant was sentenced to consecutive terms of imprisonment of life, fifty years, and fifty years. Appellant appealed, contending that the trial court committed a speedy trial violation and did not follow the strict dictates of Ark. R. Crim. P. 28.3(b)(1). The Supreme Court affirmed, holding that Appellant’s trial date was well within the one-year period for a speedy trial, as the State met its burden to prove that any delay was excludable for speedy-trial purposes, and therefore, there was no speedy-trial violation in this case. View "Carter v. State" on Justia Law

Appellant was convicted of kidnapping, aggravated residential burglary, and other offenses. Appellant was sentenced to fifty-two years’ imprisonment, which included a firearm enhancement. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The circuit court denied relief without holding a hearing. The Supreme Court affirmed, holding (1) Appellant did not establish that his trial counsel was ineffective for failing to pursue and actual-innocence defense where Appellant’s counsel actually pursued an actual-innocence defense at trial; (2) Appellant failed to demonstrate prejudice due to trial counsel’s failure to move for a change of venue; (3) Appellant’s sentence for employing a firearm in the commission of an offense was not void as the result of ineffective assistance of trial counsel; and (4) considering the totality of the evidence, the circuit court did not clearly err in denying Appellant’s request for an evidentiary hearing. View "Van Winkle v. State" on Justia Law

After a second jury trial, Appellant was convicted of four counts of rape. The court of appeals affirmed. Appellant subsequently filed an Ark. R. Crim. P. 37 petition, alleging ineffective assistance of counsel. Appellant’s petition contained three allegations of deficient performance during the second jury trial. The circuit court denied the petition without a hearing, concluding that the first allegation was conclusory and the remaining allegations were matters of trial strategy and could not form the basis for postconviction relief. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the circuit court correctly found that the first allegation could not form the basis for postconviction relief; but (2) Appellant’s second and third claims for relief based on ineffective assistance of counsel were colorable claims. Remanded for a hearing on Appellant’s second and third claims. View "Sandrelli v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder. The jury sentenced Defendant to death. The Supreme Court affirmed. Thereafter, Defendant filed a petition pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court granted Defendant a new sentencing hearing based on counsel’s admission that his performance had been inadequate. The court, however, denied Defendant relief on the basis that counsel should have presented a defense of mental disease or defect. The State appealed from the first finding, and Defendant appealed from the second finding. The Supreme Court (1) reversed on appeal, holding that the circuit court analyzed the case under a subjective legal standard rather than assessing counsel’s performance under an objective standard; and (2) affirmed on cross-appeal, holding that the circuit court did not err in denying relief based on counsel’s failure to present an affirmative defense. View "State v. Lacy" on Justia Law

Appellant was convicted of possession of a Schedule III substance with the purpose to deliver, possession of a Schedule III substance, and possession of drug paraphernalia. Appellant appealed the denial of his motion to suppress evidence obtained as a result of a canine sniff conducted after he was pulled over for failing to use a turn signal. The Supreme Court reversed Appellant’s convictions and sentence, holding that the circuit court erred in denying Appellant’s motion to suppress where the canine sniff was conducted after Appellant’s continued detention that was conducted without reasonable suspicion. View "MacKintrush v. State" on Justia Law

Appellant pled guilty to one count of sexual assault in the first degree and was sentenced to thirty years’ imprisonment. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that defense counsel was ineffective on seven separate grounds. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to assert that but for any alleged ineffectiveness on the part of counsel he would not have pleaded guilty and would have gone to trial; and (2) the circuit court did not clearly err in denying Appellant’s petition without holding an evidentiary hearing. View "Wood v. State" on Justia Law