Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of second-degree murder and possession of a firearm by certain persons. Appellant subsequently filed a pro se petition for postconviction relief. Circuit Judge Susan Hickey scheduled a hearing on the petition, but prior to the date of the hearing, Judge Hickey resigned her seat as judge. On November 21, 2011, Circuit Judge Hamilton Singleton denied Appellant's petition without a hearing. Appellant filed two motions for reconsideration, requesting the circuit court set aside its order and hold a hearing on the petition as originally scheduled by Judge Hickey. Appellant's first and second motions were denied. On March 28, 2012 Appellant filed a notice of appeal from the circuit court's order denying his petition for postconviction relief. The Supreme Court dismissed Appellant's appeal, holding that it was untimely in this case. View "Lovett v. State" on Justia Law

Appellant was an inmate in the Department of Correction serving a life sentence. Appellant filed a complaint against the governor, the chairman of the parole board, and the chairman of the board of correction seeking a declaratory judgment, injunctive relief against Defendants for civil-rights violations, and relief as a taxpayer for an illegal exaction based on claims concerning the procedures for submission of applications for clemency. The circuit court dismissed the complaint for failure to state a claim upon which relief may be granted. Appellant appealed and filed motions related to his appeal. The Supreme Court denied the motions and affirmed the circuit court's dismissal of the complaint, holding that the court did not abuse its discretion in concluding that Appellant failed to state a claim on the three bases that Appellant raised in this appeal. View "Holloway v. Beebe" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder and first-degree battery and failure to stop after an accident with injury or death. Appellant appealed, contending that the trial court erred by refusing to instruct the jury on the offense of felony manslaughter, which he argued was a lesser-included offense of felony murder. In so arguing, Appellant contended that although Perry v. State and Hill v. State supported the trial court's ruling, those cases ignored Ark. Code Ann. 5-2-203(b). The Supreme Court affirmed, holding (1) the Court would not accept Appellant's invitation to overrule Perry and Hill; and (2) the Court's felony-murder jurisprudence is in concert with the legislature's mandate stated in section 5-2-203(b). View "Holian v. State" on Justia Law

Petitioner was convicted of eleven counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The court imposed an aggregate sentence of 108 months' imprisonment. Petitioner did not appeal the sentencing order and subsequently sought leave to proceed with a belated appeal. In his motion, Petitioner asserted that his appointed attorney did not provide effective assistance of counsel and that the evidence was insufficient to sustain the judgment. The Supreme Court denied the motion, holding that Petitioner did not demonstrate good cause to permit him to proceed with a belated appeal, as Petitioner's allegation concerning his attorney's effectiveness at trial and his claim of actual innocence were not matters to be addressed in a proceeding for a belated appeal. View "Davis v. State" on Justia Law

Petitioner was convicted of three counts of rape and three counts of terroristic threatening. The convictions were affirmed on direct appeal. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecution withheld evidence of reports and transcripts of the victims' statements and that this was a violation of Brady v. Maryland. The Supreme Court denied the writ, holding that Petitioner did not establish a Brady violation because Petitioner's claim that the materials were not made available to his defense did not appear meritorious. View "Sparks v. State" on Justia Law

Appellant was convicted of rape and sentenced to 300 months' imprisonment. The Supreme Court affirmed Appellant's conviction and sentence, holding that the circuit court did not err in (1) denying Appellant's motion in limine to suppress statements he made to his psychotherapist and the medical records pertaining to his treatment, as the argument was not preserved for appellate review; and (2) granting the State's motion in limine to exclude any instance of abuse that might have occurred after the victim turned fourteen years old, as Appellant failed to preserve his argument that the evidence would have been relevant and admissible to impeach the victim's credibility. View "Riley v. State" on Justia Law

Petitioner was convicted of two counts of rape and sentenced to an aggregate sentence of 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel at trial. The Supreme Court denied the petition, holding that Petitioner's allegation was outside the purview of a coram-nobis proceeding, and to the extent that Petitioner may have intended his claims to be an attack on the sufficiency of the evidence or the credibility of witnesses, such issues were also not cognizable in coram-nobis proceedings. View "McDaniels v. State" on Justia Law

Appellant was convicted of delivery of a controlled substance and sentenced to an enhanced sentence of forty years' imprisonment and a fine. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief and, later, a motion to correct an illegal sentence. Both requests were denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus raising double-jeopardy claims. The circuit court denied the petition. Appellant appealed and filed with the Supreme Court a motion for extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant's claims were not cognizable in a petition for habeas corpus. View "Khabir v. Hobbs" on Justia Law

Appellee was charged with felony possession of drug paraphernalia and misdemeanor possession of a controlled substance. The charges stemmed from a probationary search of the bedroom he rented and sometimes shared with his girlfriend, a probationer. Appellee moved to suppress the evidence on the basis that the warrantless search of his bedroom was conducted without his consent, without probable cause, and without exigent circumstances. After a hearing, the circuit court ruled that the State failed to prove the reasonableness of the warrantless, probationary search as to Appellee because Appellee did not expressly consent to the search. The Supreme Court dismissed the State's appeal, holding that resolution of this case turned on application of its unique facts to the law, and therefore, the correct and uniform administration of the criminal law did not require the Court's review. View "State v. Myers" on Justia Law

Appellee's husband, a parolee, resided with Appellee. After a parole agent determined that a parole search of the residence was warranted, the parole officer and other police officers searched the residence. Appellee was subsequently charged with possession of methamphetamine and possession of drug paraphernalia. Prior to trial, Appellee filed a motion to suppress, alleging (1) police officers conducted the search without a warrant, without consent, and without reasonable cause; and (2) her arrest exceeded the authority of the parole officer. The circuit court granted Appellee's motion to suppress, ruling that reasonable grounds for a parole search must exist and more-than-minimal police involvement was necessary in the parole search at issue. The Supreme Court dismissed for lack of a proper State appeal where (1) the State's appeal involved only the application of a rule or statute; and (2) because the trial court acted on a mixed question of law and fact, the matter was not appealable by the State. View "State v. Jones" on Justia Law