Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without the possibility of parole. For his sole point on appeal, Appellant argued that the circuit court erred in denying his motion to suppress the evidence obtained from a search warrant that resulted in the search of the contents of his cell phone. The Supreme Court affirmed, holding that, based on the facts of this case, there was adequate probable cause to issue the search warrant of Appellant’s cell phone records and that the resulting search was proper. View "Johnson v. State" on Justia Law

After a second trial, Defendant was found guilty of first-degree murder, second-degree battery, and aggravated assault. The court of appeals affirmed the convictions and sentences. Defendant subsequently filed a timely petition for postconviction relief claiming that he had received ineffective assistance of counsel because counsel had failed to request various jury instructions and because counsel was ineffective with respect to his handling of evidentiary issues. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Defendant’s claims of ineffective assistance of counsel and in denying Defendant’s petition without a hearing. View "Sims v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery, theft of property, first-degree battery, and committing a terroristic act in connection with a drug buy. Appellant was sentenced to a total of eighty-seven years in the Arkansas Department of Correction. The court of appeals affirmed. Appellant subsequently filed a petition under Ark. R. Crim. P. 37, alleging ineffective assistance of appellate counsel and that he was improperly convicted of both aggravated robbery and first-degree battery because the first-degree battery charge is a lesser-included offense of aggravated burglary. The State conceded that Appellant was subjected to double jeopardy on the charges of aggravated robbery and first-degree battery. The circuit court denied Appellant’s claim of ineffective assistance of counsel and dismissed the offense of battery in the first degree. The Supreme Court affirmed, holding that appellate counsel provided constitutionally effective assistance. View "Taylor v. State" on Justia Law

After a jury trial, Appellant was found guilty of commercial burglary and criminal mischief in the first degree. Appellant subsequently filed a timely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting that his defense counsel provided ineffective assistance. The circuit court denied the Rule 37.1 petition without holding an evidentiary hearing. Appellant filed a notice of appeal and filed a motion seeking leave to introduce case law. The Supreme Court denied the motion and affirmed the circuit court’s order, holding that the circuit court (1) did not err in dismissing the petition without an evidentiary hearing; and (2) did not err in finding that counsel rendered effective assistance during trial. View "McLaughlin v. State" on Justia Law

After a jury trial, Defendant was found guilty of the rape of his daughter. The court of appeals affirmed. Defendant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was denied effective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s request for relief where Defendant failed to establish that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Henson v. State" on Justia Law

Plaintiffs-taxpayers were indebted to the state for delinquent tax debts. The Department of Finance & Administration filed certificates of indebtness against Plaintiffs with respect to the tax delinquencies and assessed interest on Plaintiffs prior to and after the filing of certificates of indebtedness. Plaintiffs filed a complaint for declaratory and injunctive relief against Defendant, in his official capacity as Director of the Department, alleging illegal-exaction claims and due-process violations. Defendant moved to dismiss the complaint pursuant to Ark. R. Civ. P. 12(b)(1) and (6), alleging that Appellants had failed to plead facts necessary to establish subject-matter jurisdiction and failed to plead facts on which relief may be granted. The circuit court dismissed with prejudice Appellants’ complaint. The Supreme Court affirmed, holding that the circuit court did not err in (1) dismissing Appellants’ illegal-exaction claims where Appellants did not claim that the underlying tax delinquency was illegal; and (2) ruling that Appellants failed to plead facts to support their due-process-violation claims. View "Sanford v. Walther" on Justia Law

Game wardens conducted an investigation into Appellant’s compliance with hunting laws. After the investigation was completed, the officers began a criminal investigation seeking information to determine whether Appellant was a felon. Upon discovering that he was a felon, the officers arrested and searched Appellant. Appellant filed a motion to suppress, arguing that he was unlawfully detained and unlawfully searched because the game wardens had neither a warrant nor a reasonable suspicion of any violation of law. The circuit court denied the motion. The Supreme Court agreed with Appellant and reversed, holding that, under the circumstances of this case, the officers did not have reasonable suspicion to conduct a criminal investigation. Remanded. View "Pickle v. State" on Justia Law

After a jury trial in 1995, Appellee was convicted of capital murder and sentenced to a mandatory life sentence without the possibility of parole. In 2013, Appellee filed a petition for writ of habeas corpus asserting that his sentence to life imprisonment was illegal pursuant to Miller v. Alabama because he was a juvenile at the time of the offense. The circuit court granted Appellee’s petition, vacated and set aside his offense, and reinvested the circuit court that convicted Appellee with jurisdiction to conduct resentencing proceedings. The Supreme Court reversed and remanded, holding that the circuit court had not followed the procedures mandated by the habeas-corpus statutes. On remand, the circuit court held a hearing and ruled that Appellee was entitled to relief. The Supreme Court affirmed, holding (1) the circuit court did not err by concluding that Miller applies retroactively; and (2) the circuit court’s ruling regarding equal protection and due process was not in error. View "Kelley v. Gordon" on Justia Law

After a jury trial, Appellant was found guilty of possession of drug paraphernalia with intent to manufacture methamphetamine and possession of drug paraphernalia. Appellant was sentenced to a total of 144 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37, alleging ineffective assistance of counsel. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) trial counsel erred by failing to object to the prosecutor’s statement that the jury had not “heard both sides yet” but, even assuming that the statement was improper, Appellant failed to show that she was prejudiced by the statement; and (2) the Court declined to overrule previous decisions refusing to apply the cumulative-error doctrine to claims of ineffective assistance of counsel. View "Houghton v. State" on Justia Law

Defendant was charged with the first-degree murder of John Davis. The jury found Defendant guilty of the lesser-included offense of second-degree murder. The court of appeals affurned, concluding that substantial evidence supported the jury’s finding that Defendant acted with the purpose to seriously injure Davis. Defendant subsequently filed a verified, pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant received effective assistance of counsel; and (2) Defendant’s remaining arguments were not cognizable under Rule 37.1. View "Hooks v. State" on Justia Law