Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of domestic battery in the first degree. Appellant subsequently filed a pro se petition for postconviction relief, which the trial court denied without a hearing. The Supreme Court affirmed the denial, holding (1) the trial court did not err by not appointing an attorney to represent Appellant on his postconviction petition; (2) Appellant’s challenge to his sentence was not cognizable in a postconviction proceeding; and (3) the trial court did not err in holding that Appellant’s counsel did not provide ineffective assistance under the standard set forth in Strickland v. Washington. View "Ellis v. State" on Justia Law

Defendant entered a conditional guilty plea to trafficking a controlled substance. The court of appeals affirmed. Defendant subsequently filed a petition for review, arguing that the circuit court erred in failing to suppress evidence seized during a traffic stop of the rental cae Defendant was driving because the law enforcement’s placement of a GPS tracking device on the vehicle without a warrant and gathering data about the vehicle’s movements was an unconstitutional search under United States v. Jones. The Supreme Court affirmed without considering Defendant’s argument that planting the GPS device was an unreasonable search under Jones, holding (1) Defendant had no legitimate expectation of privacy in the vehicle and no standing to challenge the search of the rental car; and (2) although Defendant had standing to challenge his own detention, the detention was reasonable. View "Wilson v. State" on Justia Law

After a jury trial, Defendant was found guilty of capital murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence. Later, Defendant petitioned the Supreme Court to reinvest jurisdiction in the circuit court to allow him to seek a writ of error coram nobis, alleging that he was incompetent at the time of trial and that the prosecutor had withheld exculpatory evidence in violation of Brady v. Maryland. The Court granted Defendant permission to pursue coram nobis relief on both grounds. The circuit court denied the petition for writ of error coram nobis, finding that Defendant had been competent to stand trial and that the prosecution did not fail to disclose exculpatory evidence. The Supreme Court reversed, holding that the circuit court abused its discretion in denying Defendant’s petition where the record illustrated that Defendant’s cognitive deficits and mental illnesses interfered with his ability to effectively and rationally assist counsel. Remanded for a new trial. View "Newman v. State" on Justia Law

After a jury trial, Petitioner was found guilty of several offenses, including rape and kidnapping. The court of appeals affirmed. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition and an amended petition requesting that the Supreme Court reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of coram nobis. The Supreme Court denied the petition and amended petition and declared the motions filed in connection with the petitions moot, holding that Petitioner’s allegations did not warrant issuance of a writ of error coram nobis. View "Hooper v. State" on Justia Law

Appellant was convicted of premeditated and deliberated capital murder and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, alleging that his trial attorney provided ineffective assistance. The circuit court denied the petition after an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of establishing that he was entitled to appointment of counsel in his postconviction proceedings; and (2) the circuit court did not abuse its discretion in denying Appellant’s motion to file an enlarged petition. View "Evans v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. Appellant was sentenced to life imprisonment without parole. On appeal, Appellant argued that the trial court erred when it admitted into evidence an out-of-court statement by a witness to a police detective. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due, in part, to trial counsel’s failure to confront the witness in cross-examination. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in connection with the appeal, holding that Appellant failed to demonstrate that counsel provided ineffective assistance. View "Davis v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder, attempted capital murder, and possession of a controlled substance. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions and sentences, holding that the circuit court did not commit reversible error by (1) allowing the State to present evidence of bad acts and bad character; (2) admitting two photographs of a large tattoo on Defendant’s back; (3) permitting repeated showings of dash-camera videos depicting the crimes as they took place; (4) failing to sequester victim-impact witnesses during the guilt phase of trial; (5) overruling Defendant’s objection to a comment the prosecuting attorney made at the sentencing phase of trial; and (6) denying Defendant’s motion to prohibit the State from seeking or imposing the death penalty. View "Lard v. State" on Justia Law

After a jury trial in 2006, Appellant was convicted of capital murder, aggravated robbery, attempted arson, and theft of property. Appellant was sentenced to an aggregate term of life imprisonment without parole plus 636 years. In 2013, Appellant filed a pro se motion for a new sentencing hearing, asserting that her trial counsel erred by not informing her of a plea bargain offered by the prosecution until after she had been convicted. The trial court denied the motion. The Supreme Court affirmed on the basis that the petition was not timely filed, and therefore, the trial court had no jurisdiction to grant the relief sought. View "Young v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a pro se petition for declaratory judgment and injunctive relief against Appellees, certain ADC correctional officers, alleging excessive use of force, negligence, failure to protect, and due-process and equal-protection violations. The circuit court granted Appellees' motion to dismiss on the ground that allowing Appellant to proceed with the action in forma pauperis would violate the three-strike rule embodied in Ark. R. Civ. P. 9(b). Appellant appealed, arguing that the circuit court erred in dismissing his complaint and that the "imminent danger" exception to the three-strike rule applied. The Supreme Court affirmed, holding that Appellant failed to demonstrate any error in the dismissal of his complaint. View "Pitts v. Rafter" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced as a habitual offender to life imprisonment. Appellant appealed, arguing that the circuit court erred in denying his motion to suppress an incriminating statement that he made after he unequivocally invoked his right to remain silent. The Supreme Court affirmed, holding that Appellant's statement that he had already told officers all the he knew during an interrogation was not an unambiguous and unequivocal invocation of his right to remain silent, and therefore, the trial court did not err in denying the motion to suppress. View "Fritts v. State" on Justia Law