Justia Arkansas Supreme Court Opinion Summaries

Defendant was charged with drug and firearm offenses. Defendant filed a motion to suppress the items discovered during a search of his person and his minivan. The circuit court granted the motion after a hearing. The State appealed, arguing that the circuit court erred as a matter of law (1) by concluding that additional officer testimony was required to support the pat down of Defendant, and (2) when it found that a warrant was required to search a locked safe discovered in Defendant’s minivan. The Supreme Court dismissed the appeal in part and reversed and remanded in part, holding (1) the State’s first point on appeal is not appealable because it involves the circuit court’s consideration of the particular facts of the case and its determination that those facts did not justify the search of Defendant’s person; and (2) the circuit court erred as a matter of law in finding that, absent exigent circumstances, a warrant was required to search the safe in Defendant’s minivan. View "State v. Crane" on Justia Law

After a jury trial, Appellant was convicted of kidnapping. Appellant was sentenced to life imprisonment. Appellant filed a motion for new trial based on juror misconduct, alleging that a certain juror had used her cell phone to post on a social media website during jury deliberation in violation of the circuit court’s instructions not to do so. After a hearing, the circuit court granted Appellant’s motion for new trial, concluding that by posting to Facebook, the juror had disregarded and violated the court’s clear orders and that, as a result, Appellant had not received a fair trial. The Supreme Court dismissed the State’s appeal, holding that the Court did not have jurisdiction over the appeal, as it turned on whether the circuit court’s findings were supported by the unique facts in this case and did not involve the correct and uniform administration of the law. View "State v. Riley" on Justia Law

After a jury trial, Appellant was convicted of delivery of cocaine. The court of appeals affirmed the conviction. Appellant subsequently filed an Ark. R. Crim. P. 37.1 petition, raising several allegations of ineffective assistance of trial counsel, including claims that trial counsel was ineffective for (1) failing to effectively communicate and inform him of a global plea offer, (2) failing to make a proper Batson challenge, (3) failing to pursue a motion to be relieved as counsel, and (4) not being adequately prepared for trial. The circuit court denied postconviction relief. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying relief. View "Mister v. State" on Justia Law

In 2001, Appellant was sentenced on each of three controlled-substance offenses, and in 2007, Appellant was sentenced on each of three controlled-substance offenses. In 2010, the State petitioned to revoke Appellant’s six suspended sentences for the controlled-substances convictions. The circuit court granted the petition, and Appellant was sentenced to a total of fifty-seven years’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, The circuit court denied relief. Appellant appealed, arguing that his trial counsel provided ineffective assistance because counsel never explained to him his maximum sentencing exposure and also misled him about a plea offer. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying relief. View "Mister v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The judgment was affirmed on appeal. Appellant subsequently filed an amended pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was not afforded effective assistance of counsel at trial. After an evidentiary hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the claims raised by Appellant were largely devoid of the factual support required for a finding of ineffective assistance of counsel, and therefore, the trial court did not err in denying relief under Rule 37.1. View "Jones v. State" on Justia Law

Appellant entered a negotiated plea of guilty to one count of first-degree murder and four counts of aggravated robbery. Appellant was sentenced to life imprisonment for each of the charges. The sentencing orders in Appellant’s case referred to Appellant’s parole eligibility after serving one-third of his life sentences. However, parole eligbility was not authorized by the statute in effect at the time the crimes were committed. Appellant filed a petition for writ of habeas corpus, which was denied. On reconsideration, the Supreme Court granted the writ, holding that the sentencing orders entered against Appellant were facially invalid because the circuit court exceeded its authority in sentencing Appellant to life imprisonment with the possibility of parole. Remanded for resentencing. View "Pennington v. Hobbs" on Justia Law

After a jury trial, Defendant was convicted of one count of delivery of cocaine. Defendant was sentenced as a habitual offender to 480 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief 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, holding (1) the circuit court did not err in denying the petition without a hearing; and (2) based on the standard established in Strickland v. Washington, the circuit court did not err in finding that counsel’s performance was not constitutionally defective. View "Nalls v. State" on Justia Law

After the General Assembly passed Act 595 of 2013, Appellees, registered voters in Pulaski County, filed a complaint for injunctive and declaratory relief, arguing that sections of the Act that allegedly placed an additional qualification and impairment on Arkansas residents before they could exercise their right to vote violated the Arkansas Constitution. The circuit court concluded that Act 595 was unconstitutional, enjoined and restrained Appellants, the Secretary of State and the Commissioners of the State Board of Election Commissioners, from enforcing any proof-of-identity provisions of the Act and from enforcing their rules promulgated as a result of the Act, and granted a preliminary injunction against Appellants from enforcing Act 595’s proof-of-identity requirements in favor of Appellants. The Supreme Court affirmed the circuit court’s ruling that Act 595 was unconstitutional on its face, holding that the Act’s requiring proof of identity was unconstitutional on its face and imposed a requirement that fell outside the ambit of Ark. Const. art. III, 1. View "Martin v. Kohls" on Justia Law

After a jury trial, Appellant was found guilty of the rape of twenty-three-year-old J.H., who was incapable of consent by virtue of her mental age of six or seven years. Appellant was sentenced to 840 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel at trial. The trial court denied the petition after a hearing. The Supreme Court affirmed, holding that Appellant failed to establish that his counsel’s performance was deficient in any respect. View "Stewart v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder, aggravated residential burglary, kidnapping, and rape. Appellant was sentenced to life without parole for the capital murder conviction. On appeal, Appellant argued that the circuit court erred in denying his objection to the State’s use of peremptory challenges in violation of Batson v. Kentucky. Specifically, Appellant claimed that there was purposeful discrimination in that six of the eight strikes used by the State were strikes of black potential jurors, which resulted in Appellant, an African American, being tried by an all-white jury. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Appellant’s Batson challenge. View "McMiller v. State" on Justia Law