Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of commercial burglary, theft of property, and fraud. Appellant was sentenced as a habitual offender to serve an aggregate term of 1,200 months’ imprisonment. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied relief after a hearing. The Supreme Court affirmed, holding (1) the trial court did not err in correcting the sentencing order to reflect that Appellant was sentenced as a habitual offender under Ark. Code Ann. 5-4-501(b) rather than section 5-4-501(a); and (2) Appellant’s counsel did not provide ineffective assistance. View "Fletcher v. State" on Justia Law

After a jury trial in 1983, Petitioner was found guilty of murder in the first degree and aggravated robbery. Petitioner was sentenced as a habitual offender to an aggregate term of life imprisonment. In 2005, Petitioner filed a pro se petition requesting permission to proceed in the trial court with a petition for writ of error coram nobis. The petition was denied. Petitioner then filed a second petition requesting permission to proceed in the trial court with a petition for writ of error corm nobis. The Supreme Court denied the petition, holding (1) to the extent Petitioner again alleged a Brady violation and asserted that erroneous evidence was used to establish that he was a habitual offender, these two claims were asserted in Petitioner’s first petition and were an abuse of the writ; (2) Petitioner’s remaining claims were either without merit or outside the purview of a coram-nobis proceeding; and (3) even if Petitioner had presented grounds sufficient to support issuance of the writ, his failure to act with due diligence would constitute good cause to deny the petition. View "Williams v. State" on Justia Law

In 2006, judgment was entered reflecting Appellant’s jury convictions for possession of cocaine, simultaneous possession of drugs and firearms, and possession of a firearm by a felon. Appellant filed a petition for writ of habeas corpus, asserting two grounds for the writ that were based on allegations of double jeopardy violations resulting from the convictions for possession of cocaine and simultaneous possession of drugs and firearms. The circuit court dismissed the petition, concluding that the claims were not cognizable in a petition for writ of habeas corpus. The Supreme Court affirmed, holding that the circuit court did not err in denying relief because there was no double jeopardy violation in Appellant’s challenged convictions, and the two convictions did not impose an illegal sentence. View "White v. State" on Justia Law

In 2013, the General Assembly passed Act 1413 of 2013, which made numerous changes to the portions of the Arkansas Code pertaining to initiatives and referenda. Plaintiffs subsequently filed a complaint against Mark Martin, in his official capacity as the Secretary of State, alleging that certain sections of the Act violated the Seventh Amendment of the state Constitution. Plaintiffs moved for a preliminary injunction seeking to enjoin Secretary Martin from enforcing the Act. Dustin McDaniel, acting in his official capacity as Attorney General, intervened in the action. The circuit court concluded that certain provisions of Act 1413 violated the Constitution because the provisions would cause citizens to lose their ability to propose legislative measures and laws directly to the people. The court then permanently enjoined Secretary Martin from enforcing those portions of the Act. The Supreme Court affirmed in part and reversed in part, holding that some of the sections of the Act declared unconstitutional by the circuit court were, in fact, constitutional. View "McDaniel v. Spencer" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder as an accomplice and sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging that he received ineffective assistance of counsel. The circuit court denied the petition after a hearing. Appellant appealed, contending that the circuit court erred in denying postconviction relief because he would have accepted the State’s plea offer had his counsel disclosed the evidence against him. The Supreme Court affirmed, holding that Appellant failed to prove any deficiency on the part of his trial counsel. View "Camp v. State" on Justia Law

Appellant pleaded guilty to a single count of rape pursuant to a plea agreement. Appellant was sentenced to twenty-five years in prison, the minimum sentence he could have received, plus a suspended imposition of sentence of fifteen years. Appellant filed a petition pursuant to Ark. R. Crim. P. 37 alleging that his counsel had provided ineffective assistance by advising him that he would be eligible for parole in five years and would serve no more than eight years and that he would have refused to plead guilty had he known he would be required to serve at least seventy percent of his sentence before becoming eligible for parole. The circuit court denied the petition, concluding that Appellant had been correctly advised about his eligibility for parole. The Supreme Court affirmed, holding that the circuit court did not clearly err in determining that Appellant did not receive incorrect advice regarding his eligibility for parole. View "Riddle v. State" on Justia Law

Appellant entered a negotiated plea of no contest to a charge of aggravated residential burglary and negotiated pleas of guilty to aggravated assault and felon in possession of a firearm. The circuit court accepted the pleas. Appellant subsequently filed a petition for postconviction relief alleging that he did not knowingly and voluntarily enter the pleas and that he received ineffective assistance of counsel in accepting the negotiated pleas. The circuit court rejected Appellant’s claims. The Supreme Court affirmed, holding that the circuit court did not err in (1) finding that Appellant voluntarily and knowingly entered pleas of no contest and guilty; and (2) concluding that Appellant received effective assistance of counsel. View "Young v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery and theft of property. Defendant was sentenced as a habitual offender to a term of life imprisonment. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress evidence that the police seized after entering his motel room using a key card. The officers entered the motel room to serve an arrest warrant based on an anonymous tip. The Supreme Court affirmed, holding (1) the circuit court erred in admitting the evidence seized incident to Defendant’s arrest, as the uncorroborated tip, standing alone, did not provide sufficient detail for a reasonable belief that the motel room was Defendant’s room or that Defendant was present; but (2) the error in denying Defendant’s motion to suppress was harmless beyond a reasonable doubt. View "Evans v. State" on Justia Law

In 1983, Appellant pled guilty to ten counts of aggravated robbery and one count of robbery. For one of the aggravated-robbery convictions, Appellant was sentenced to life imprisonment. In 2010, the U.S. Supreme Court held in Graham v. Florida that a sentence of life without parole on a juvenile nonhomicide offense was unconstitutional. Appellant subsequently filed a petition for writ of habeas corpus alleging that his sentence of life imprisonment for aggravated robbery was illegal. After a hearing, the circuit court granted writ of habeas corpus and reduced Appellant’s life sentence to a sentence of forty years. Appellant appealed, arguing that a person resentenced under Graham is entitled to a plenary resentencing hearing. The Supreme Court rejected this argument in Hobbs v. Turner. The Supreme Court affirmed the sentence imposed by the circuit court and declined to overrule or modify its decision in Turner, as Appellant failed to give any compelling reason to do so. View "Proctor v. Hobbs" on Justia Law

Appellant was convicted of theft of property and two counts of aggravated robbery for robbing a bank. At trial, Appellant argued that he was involuntarily intoxicated at the time of the robbery due to the combination of prescription medications he was taking. Appellant sought postconviction relief alleging that he received ineffective assistance of counsel because his attorneys failed to subpoena certain prescription records from the pharmacy, failed to subpoena a pharmacy employee who could authenticate the records, and did not request a jury instruction on the lesser-included offense of robbery, resulting in Appellant’s conviction of the greater offense of aggravated robbery. The Supreme Court affirmed, holding (1) Appellant was not prejudiced by his attorneys’ failure to procure the records or testimony regarding the prescription records; and (2) Appellant’s second argument was not preserved for appeal. View "Feuget v. State" on Justia Law