Justia Arkansas Supreme Court Opinion Summaries

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

The State charged Defendant with one count of arson. Defendant filed a motion to suppress evidence seized in a warrantless search of Defendant's burned building that was conducted three days after the fire during an insurance company investigation. Defendant asserted that law enforcement officers did not have probable cause to search the building without a search warrant, and therefore, the search was invalid. The circuit court granted Defendant’s motion to suppress, finding that certain evidence and photographs taken from the burned premises during the warrantless search violated the Fourth Amendment. The State brought this interlocutory appeal. The Supreme Court dismissed the appeal, as the appeal did not involve the interpretation of the law or the uniform administration of justice, as required by Ark. R. App. P.-Crim. 3(c). View "State v. Brashers" on Justia Law

After a jury trial, Appellant was found guilty of murder in the second degree and being a felon in possession of a firearm. Appellant was sentenced as a habitual offender to a term of imprisonment and a fine. The court of appeals affirmed. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that he was denied the effective assistance of counsel in several respects. Appellant's petition was denied. The Supreme Court affirmed, holding that Appellant failed to meet his burden of establishing that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Stalnaker v. State" on Justia Law

Appellant was the owner of gas, oil, and other minerals situated within the Ozark Highlands Unit (OHU). SEECO, Inc. applied to create a drilling unit in the OHU and to integrate all unleased and uncommitted mineral interests within the unit. The Arkansas Oil and Gas Commission established the unit and integrated all unleased and uncommitted mineral interests within the unit with the exception of Appellant’s unleaded mineral interests. At a hearing before the Commission to hear evidence related to SEECO’s request to integrate Appellant’s unleaded mineral interests into the drilling unit, Appellant asserted that the Commission’s forced-integration procedures amounted to a taking of his property. The Commission subsequently integrated Appellant’s unleaded mineral interests into the drilling unit. The circuit court affirmed the Commission’s decision. The Supreme Court affirmed, holding (1) the forced integration procedures do not amount to an unconstitutional taking; and (2) the Commission’s order did not deprive Appellant of his constitutional right to a jury trial to determine just compensation for his property. View "Gawenis v. Ark. Oil & Gas Comm'n" on Justia Law

After a jury trial, Petitioner was convicted of capital murder, residential burglary, attempted capital murder, rape, and aggravated robbery. Petitioner was sentenced to death for the capital murder conviction. The Supreme Court affirmed Petitioner’s convictions and sentences. Petitioner sought postconviction relief under Ark. R. Crim. P. 37.1, and the Supreme Court affirmed the circuit court’s denial of the petition. Petitioner now petitioned the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, arguing that the prosecution withheld material evidence in violation of Brady v. Maryland. The Supreme Court granted the petition to reinvest jurisdiction, holding that the State withheld evidence that might have led counsel to utilize a defense based on an alternate suspect. View "Isom v. State" on Justia Law

Appellant entered a conditional plea of no contest to one count of misdemeanor possession of a firearm by certain persons. Appellant appealed, arguing that the circuit court erred in denying his motion to dismiss because (1) he had not been adjudicated mentally ill or involuntarily committed to a mental institution in violation of Ark. Code Ann. 5-73-103(a), and (2) section 5-73-103(a)(3) is void for vagueness, violates Appellant's due process under the federal Constitution, and violates the Second Amendment to the federal Constitution and article 2, section 5 of the state Constitution. The Supreme Court dismissed in part and affirmed in part, as (1) Appellant’s first point was not properly before the Court; and (2) Appellant’s remaining points were not raised below and ruled upon by the circuit court. View "Gooch v. State" on Justia Law

Appellant was convicted of three counts of second-degree sexual assault. The conviction was affirmed on appeal. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, raising claims of ineffective assistance of trial counsel and claims of independent constitutional error. The trial court denied postconviction relief. The Supreme Court affirmed, holding (1) Petitioner failed to make required showings under the Strickland analysis that his trial counsel provided ineffective assistance; (2) Appellant failed to demonstrate that appellate counsel was ineffective; and (3) Appellant failed to establish with factual substantiation that his claims of prosecutorial misconduct or due process violations were sufficient to void the judgment in his case, and the trial court’s findings were not clearly erroneous. View "Savage v. State" on Justia Law

After a jury trial, Appellant was convicted of four counts of fourth-degree sexual assault, possession of a firearm by a felon, two counts of fleeing, and resisting arrest. The court of appeals affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, arguing that the three attorneys who represented him at trial were ineffective. The trial court dismissed and denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the trial court was clearly erroneous in summarily denying postconviction relief. View "Magness v. State" on Justia Law

After a jury trial, Defendant was found guilty of possession of cocaine with intent to deliver, possession of marijuana with intent to deliver, and unauthorized use of property to facilitate a crime. The court of appeals affirmed. Defendant subsequently filed a petition for a new trial pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed the denial of Defendant’s Rule 37.1 petition, holding that the circuit court did not clearly err in refusing to grant relief on the points raised by Defendant. View "Smith v. State" on Justia Law