Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of capital murder and aggravated robbery and was sentenced to an aggregate term of life imprisonment without parole. Appellant later filed a pro se petition for writ of habeas corpus, bringing claims pertaining to double jeopardy, sufficiency of the evidence, ineffective assistance of counsel, and his actual innocence. The circuit court denied the habeas petition. Appellant appealed and also filed a motion for appointment of counsel to represent him on appeal. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion for appointment of counsel, holding that because Appellant did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, the circuit court did not err when it dismissed the petition. View "Gardner v. Hobbs" on Justia Law

Appellant was found guilty of rape and sentenced to life 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. After a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in declining to grant relief under Rule 37.1 under the circumstances of this case because, while counsel erred in some respects, Appellant did not demonstrate that counsel’s deficient performance so prejudiced Appellant’s defense that he was deprived of a fair trial.View "Chunestudy v. State" on Justia Law

After a jury trial in 2011, Appellant was found guilty of attempted residential burglary and sentenced as a habitual offender to 360 months’ imprisonment. In 2013, Appellant filed a pro se petition for postconviction relief, alleging that his trial counsel was ineffective by failing to investigate the jury pool and learn that two of the prospective jurors were employees of the Arkansas Department of Correction (ADC) and by failing to allow the trial court to admonish the potential jurors regarding the ADC employees as the court had offered to do. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court (1) did not err in denying the petition without holding an evidentiary hearing; and (2) did not clearly err in concluding that counsel’s performance was effective.View "Spratt v. State" on Justia Law

After a jury trial in 2011, Appellant was found guilty of murder in the first degree and possession of a firearm by a felon. The court of appeals affirmed the judgment. Appellant subsequently filed a 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 because trial counsel employed improvident trial strategy. After a hearing, the trial court declined to grant relief. The Supreme Court affirmed the trial court’s denial of Appellant’s petition, holding that Appellant did not meet his burden of demonstrating that counsel made specific errors that prejudiced the defense.View "Smith v. State" on Justia Law

After a jury trial in 2001, Appellant was found guilty of four counts of aggravated robbery, three counts of misdemeanor theft of property, and one count of felony theft of property. In 2013, Appellant filed a motion under Ark. Code Ann. 16-112-202 seeking fingerprint testing, DNA testing, and further examination of a videotape. Approximately three weeks later, Appellant filed a “motion for a new trial,” requesting that the videotape be tested under Ark. Code Ann. 16-112-208 and again requesting fingerprint and DNA testing. The trial court denied both pleadings on the ground that the two pleadings were successive habeas pleadings and subject to denial under Ark. Code Ann. 16-112-205(d). The Supreme Court affirmed, holding that the trial court did not err in denying the pleadings.View "Hutcherson v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. The Supreme Court affirmed. Sixteen years after the judgment had been entered, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, asserting that he was actually innocent of the murder and seeking DNA testing of blood on an article of clothing. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish good cause for the lengthy delay in filing his petition and that Appellant’s claim of ineffective assistance of counsel was not properly before the Court.View "Hussey v. State" on Justia Law

After a jury trial, Appellant was found guilty of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. The court of appeals affirmed. Appellant sought postconviction relief pursuant to Ark. R. Crim. P. 37.1, without success. Thereafter, Appellant, who was incarcerated at a prison facility in Lee County, filed in the Drew County Circuit Court a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, alleging that there was scientific evidence to demonstrate that he was actually innocent of the offenses of which he was convicted and that his sentence was illegal. The trial court denied the petition. Supreme Court dismissed Appellant’s appeal on the basis that the habeas petition was filed in the wrong court.View "Darrough v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder and sentenced to eighty years in prison. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37 alleging ineffective assistance of counsel. The circuit court granted relief and ordered a new trial, concluding that Appellant’s trial counsel was ineffective for failing to renew a challenge to the circuit court’s decision to exclude evidence of the victim’s prior act of violence, thus depriving Appellant of his opportunity to present a complete defense. The Supreme Court reversed, holding that the circuit court’s initial decision to exclude the evidence was not in error, and therefore, there was no basis on which to grant postconviction relief.View "State v. Rainer" on Justia Law

Appellant was convicted on two counts of capital murder and sentenced to life imprisonment. Appellant filed a petition for writ of habeas corpus setting forth a number of allegations or error. The circuit court dismissed the petition on the grounds that Appellant failed to establish probable cause for a writ of habeas corpus to issue. The Supreme Court affirmed, holding (1) Appellant’s arguments concerning the validity of the charging instruments, intertwined with other arguments concerning trial error, failed; and (2) the remainder of Appellant’s arguments were not grounds for issuance of a writ of habeas corpus. View "Sanders v. Straughn" on Justia Law

After a jury trial, Petitioner was found guilty of two counts each of attempted first-degree murder and first-degree battery. The court of appeals affirmed. Petitioner subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that, based on a totality of the evidence, the trial court did not clearly err in denying Petitioner’s petition, as Petitioner did not meet his burden of overcoming the presumption that his trial counsel was effective.View "Robinson v. State" on Justia Law