Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a plea of guilty to rape and was sentenced as a habitual offender to 720 months’ imprisonment. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the Arkansas Department of Correction (ADC), arguing that the Director denied him due process of law by applying Ark. Code Ann. 16-93-611 and 5-4-501(c) to his case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not demonstrate that both the statutory provisions requiring him to be fifty-five years of age and also to have served seventy percent of his sentence should not have been applied to his parole or transfer eligibility, or that he was entitled to any relief by means of a declaratory judgment or writ of mandamus. View "Carroll v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of first-degree battery, being a felon in possession of a firearm, and use of a firearm in commission of a felony. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. Appellant then filed a pro se petition to correct an illegal sentence, raising several allegations of error. The trial court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s claims were either not within the purview of his petition to correct an illegal sentence or without merit.View "Atkins v. State" on Justia Law

Appellant entered a plea of guilty to three counts of rape and was sentenced to three consecutive terms of life imprisonment. Appellant subsequently filed in the trial court a petition for writ of error coram nobis, arguing that the writ should issue on the ground that he was not afforded effective assistance of counsel with respect to a plea bargain that was offered to him. The trial court denied the petition. The Supreme Court affirmed, holding that the claims in the petition were clearly outside the purview of a coram-nobis proceeding, and therefore, Appellant failed to establish that the writ should issue.View "Schrader v. State" on Justia Law

In 1978, Appellant pleaded guilty to first-degree murder, four counts of aggravated robbery, and first-degree battery. Appellant received concurrent sentences of life imprisonment for the charge of murder and each of the aggravated-robbery charges. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging, among other claims, that his sentence to life imprisonment without the possibility of parole for crimes he committed when he was a minor was unconstitutional. The Supreme Court dismissed the appeal and declared moot or denied the motions filed pertaining to the appeal, holding (1) because Appellant was not subjected to a mandatory sentence of life without parole, Appellant’s sentences were not illegal under Miller v. Alabama; and (2) the remaining assertions raised by Appellant were not cognizable in a habeas proceeding.View "Pennington v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of capital murder for the death of his twenty-three-month-old son. Appellant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed the appeal and denied and mooted the motions pertaining to the appeal, holding that the trial court did not clearly err in holding that counsel’s performance was not ineffective.View "Ingram v. State" on Justia Law

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