Justia Arkansas Supreme Court Opinion Summaries

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

Appellant entered a negotiated plea of nolo contendere to one count of theft of property-credit/debit card or account number and two counts of misdemeanor fraudulent use of a credit card. Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging that trial counsel provided ineffective assistance. The Supreme Court held that it must affirm on appeal where it was unable to determine whether the trial court’s findings were sufficient concerning Appellant’s claims because the record the record was insufficient concerning all of Appellant’s points on appeal. View "Carter v. State" on Justia Law

Appellant, an inmate, filed a pro se petition for writ of habeas corpus, arguing that the writ should issue on the ground that he would not have entered a plea of guilty in his criminal case if his attorney had correctly advised him on his eligibility for parole. The claim, however, did not call into question the trial court’s jurisdiction or the facial validity of the judgment. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal and mooted the motion filed in connection with the appeal, holding that Appellant failed to state a basis upon which the writ could issue. View "Sims v. State" on Justia Law

In 2012, Appellant was found guilty of rape and sexual indecency with a minor. An aggregate sentence of 480 months’ imprisonment was imposed. The Supreme Court affirmed. In 2014, Appellant filed a pro se petition for writ of habeas corpus, contending that he was not afforded effective assistance of trial counsel and that the evidence was insufficient to sustain the judgment of conviction. The circuit court denied relief, and Appellant appealed. The Supreme Court dismissed the appeal and declared moot the motion filed in connection to the appeal, holding that Appellant failed to state a basis on which the writ could issue. View "Pruitt v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and tampering with physical evidence. The Supreme Court affirmed on all points except for the tampering with physical evidence conviction, which the Court reversed and dismissed, holding (1) Appellant’s arguments that the circuit court erred in denying his directed-verdict motions on the rape conviction were not preserved for appellate review; (2) substantial evidence did not support Appellant’s conviction for tampering with physical evidence; (3) Appellant waived his right to pursue his argument that the circuit court erred when it failed to remove a juror with ties to the rape victim’s family; and (4) the circuit court did not abuse its discretion when it declined Appellant’s request to give a lesser-included offense jury instruction for the rape charge. View "Hartman v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of aggravated robbery and one count of theft of property. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Appellant’s convictions because the State introduced ample direct and circumstantial evidence that Appellant was the person who committed the crimes; (2) the circuit court did not err in allowing the State to introduce into evidence certain audio recordings of phone conversations; and (3) the Court was precluded from reviewing either of Appellant’s assertions of ineffective assistance of counsel. View "Chatmon v. State" on Justia Law

In 1979, Appellant pleaded guilty to attempted murder and was sentenced to life imprisonment. Appellant was seventeen years old when he committed the offense. In 2011, Appellant filed a pro se complaint for declaratory relief alleging that the parole-eligibility statute was unconstitutional as applied to him because Graham v. Florida established that the Eighth Amendment prohibits the imposition of life imprisonment without parole for juvenile offenders convicted of nonhomicide offenses. The circuit court denied the complaint. Appellant appealed. The Supreme Court ordered Appellant to file a supplemental addendum, as Appellant’s addendum was deficient in that he failed to provide certain pleadings pursuant to Ark. R. Sup. Ct. 4-7. View "Bramlett v. Hobbs" on Justia Law

In 2009, Appellant was convicted of rape, sexual indecency with a child, and possessing matter depicting sexually explicit conduct involving a child. The Arkansas Department of Correction (ADC) applied Ark. Code Ann. 16-93-611 to Appellant’s sentence for the crime of rape to determine his parole-eligibility date. The court of appeals affirmed. In 2013, Appellant filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the ADC, arguing that the application of section 16-93-611(a)(1) to his sentence was an unconstitutional sentence enhancement and that he was denied due process of law by the application of the statute without notice. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because the arguments raised by Appellant in this appeal primarily stemmed from his erroneous characterization of section 16-93-611 as an enhancement statute, none of the claims for relief in Appellant’s petition demonstrated that he was entitled to any relief by means of a declaratory judgment or a writ of mandamus. View "Mason v. Hobbs" on Justia Law

In 2013, Defendant was convicted of three counts of rape, three counts of aggravated robbery, and one count of Class B felony kidnapping. Defendant’s convictions arose from three separate incidents that occurred in January, 2001. Defendant appealed, arguing that the abolition by Ark. Code Ann. 5-1-109(b)(1)(B) and (j) of the statute of limitations defense for defendants whose DNA profile is included in a DNA database violates the Equal Protection Clause. The Supreme Court affirmed, holding that the statutory provisions eliminating the statutes of limitation for DNA-identified defendants do not violate Defendant’s right to equal protection. View "Brown v. State" on Justia Law