Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of murder. The Supreme Court affirmed. Appellant then filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition after conducting an evidentiary hearing. Appellant appealed the denial of his postconviction petition. The Supreme Court affirmed, holding (1) there was no error in the adequacy of the order issued by the trial court in support of its findings dismissing Appellant’s petition; and (2) the trial court did not err in finding that Defendant received constitutionally effective assistance of counsel. View "Anderson v. State" on Justia Law

After a jury trial in 1989, Appellant was found guilty of murder in the first degree and sentenced as a habitual offender to 200 years’ imprisonment. In 2000, Appellant filed a pro se petition for writ of habeas corpus alleging that the 200-year sentence exceeded the statutory maximum sentence for first-degree murder and was thus illegal. The Supreme Court denied the petition, holding that the sentence was within statutory range. In 2014, Appellant filed a pro se petition for writ of habeas corpus, raising seven claims. The circuit court denied the petition. the Supreme Court affirmed, holding (1) Appellant’s claim that his sentence was excessive had already been addressed; and (2) the remaining allegations raised by Appellant were not cognizable in a habeas proceeding. View "Scott v. State" on Justia Law

After a jury trial, Appellant was found guilty of sexual indecency with a child and sexual assault in the second degree. After the conviction was affirmed on appeal, Appellant filed a petition for postconviction relief, alleging, among other things, that his counsel provided ineffective assistance. The trial court dismissed the petition, concluding that it was untimely filed. This appeal concerned Appellant’s third pro se petition for postconviction relief in which he made essentially the same allegations as he raised in his first postconviction petition. The trial court denied and dismissed the petition, ruling that Appellant could not file a subsequent petition for postconviction relief when a postconviction petition alleging essentially the same claims had already been denied as being untimely. The Supreme Court affirmed, holding that because Appellant did not appeal from the order dismissing his first petition as untimely, his third petition was likewise untimely, and the trial court had no jurisdiction to grant the relief sought. View "Newton v. State" on Justia Law

Gloria Daniel was fired from her position as a registered nurse at the Arkansas State Hospital thirteen months after she reported to Charles Smith, the hospital’s administrator, that a patient’s death was attributable to abuse or neglect on the part of the hospital. Daniel filed suit, asserting claims under the Arkansas Whistle-Blower Act, the Arkansas Civil Rights Act, and federal law, naming as Defendants Smith in his individual and official capacities, and Betty Mains in her official and individual capacities as the hospital’s assistant administrator. The circuit court concluded that Daniel’s claim for retaliation was not barred by sovereign immunity and that Defendants were not entitled to qualified immunity. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) did not err in denying Defendants’ motion for summary judgment based on sovereign immunity; and (2) erred in denying Defendants’ motion for summary judgment to dismiss the individual-capacity claims based on qualified statutory immunity grounds. View "Smith v. Daniel" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, claiming actual innocence, challenging the sufficiency of the evidence to support his conviction, and alleging that the circuit court lacked subject-matter jurisdiction to retry his case because of a speedy-trial violation. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish a basis for a finding that a writ of habeas corpus should issue. View "Hubbard v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment, plus fifteen years for a firearm enhancement. The Supreme Court affirmed the convictions and sentence, holding (1) there was substantial evidence to support Appellant’s conviction for first-degree murder, and the circuit court did not err in denying Appellant’s motion for directed verdict; (2) the circuit court did not err in denying Appellant’s motion to suppress his statements; and (3) the circuit court did not err in denying Appellant’s motion in limine to exclude certain photographs that Appellant claimed were irrelevant and more prejudicial than probative.` View "Airsman v. State" on Justia Law

In 1998, Appellant pleaded guilty to multiple felony offenses and was sentenced to an aggregate term of life imprisonment without parole. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. In 2010, Appellant filed in the trial court a petition for writ of error coram nobis, arguing that he was denied effective assistance of counsel when he entered his guilty plea and during his Rule 37.1 proceeding. The trial court denied the petition. Now before the Supreme Court were Appellant’s pro se motion for extension of time to file his brief-in-chief and his petition for writ of certiorari in which he urged the Court to find that the trial court erred in denying his petition for writ of error coram nobis. The Supreme Court dismissed the appeal and declared the motion and petition moot, holding that Appellant failed to establish a sufficient ground for issuance of the writ. View "Millsap v. State" on Justia Law

Appellant entered a negotiated plea of guilty in one case to fleeing on foot and possession of methamphetamine and to residential burglary and robbery in another case. Appellant subsequently filed a pro se petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 that encompassed both cases, claiming that his counsel provided ineffective assistance when he entered his plea to the four offenses. The trial court denied postconviction relief. The Supreme Court affirmed the denial of postconviction relief, holding that the claims raised by Appellant in his postconviction motion and argued on appeal were without merit. View "Sherman v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of raping his seven-year-old stepdaughter. After the mandate issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging, among other claims, ineffective assistance of counsel. The trial court dismissed the petition after a hearing. The Supreme Court affirmed, holding (1) the trial court did not clearly err in holding that counsel’s performance was not ineffective; (2) the trial court correctly held that Appellant’s claim of prosecutorial misconduct at trial was not cognizable in a Rule 37.1 proceeding; and (3) Appellant’s claim that he was dissatisfied with his attorney’s representation in the Rule 37.1 proceeding was not grounds to reverse the trial court’s order and remand for a new hearing. View "McNichols v. State" on Justia Law

Appellant, an inmate of the Arkansas Department of Correction, was found guilty of capital murder in the stabbing death of a fellow inmate. Appellant filed a pro se petition for writ of habeas corpus, arguing that the trial court made several errors in its rulings on defense motions during voir dire and during trial and that his counsel provided ineffective assistance. The circuit court dismissed the petition, noting that the action counted as a “strike” pursuant to Ark. Code Ann. 16-68-607. The Supreme Court affirmed, holding (1) Appellant did not show that the court failed to address any issue cognizable in a habeas proceeding; (2) Appellant’s claims of trial error and ineffective assistance of counsel were not within the purview of a habeas proceeding; and (3) inasmuch as Appellant’s petition for writ of habeas corpus failed to state a claim on which relief was merited, the circuit court did not err in declaring that the petition constituted a strike under the statute. View "Tucker v. Hobbs" on Justia Law