Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a negotiated plea of guilty to the offense of rape. More than four years after the judgment had been entered, Appellant filed a motion to withdraw a guilty plea under Ark. R. Crim. P. 26.1, which the circuit court denied as untimely. Appellant appealed and filed a motion to file a belated brief, in which he sought to file a nonconforming brief that he tendered in the appeal. The Supreme Court dismissed the appeal and declared the motion moot, holding that, as the petition was untimely filed, the trial court lacked jurisdiction to grant postconviction relief, and therefore, the Supreme Court also lacked jurisdiction. View "Winnett v. State" on Justia Law

Petitioner was convicted of possession of cocaine with intent to deliver, possession of methamphetamine with intent to deliver, and maintaining a drug premises. Subsequently, Petitioner, through counsel, filed a petition that sought a writ of error coram nobis or, alternatively, a writ of certiorari or recall of the mandate. In the petition, Petitioner requested that the Supreme Court assume jurisdiction of the cause rather than reinvest jurisdiction in the trial court. The Supreme Court denied the petition, holding (1) Petitioner failed to meet the criteria necessary to grant the relief he requested; and (2) Petitioner failed to make an argument that could support an exception to the requirements for issuing any of the writs or remedies he requested. View "Turner v. State" on Justia Law

Appellant pled guilty to a charge of aggravated robbery, pursuant to a negotiated plea agreement, and was sentenced to 180 months' incarceration. Subsequently, Appellant filed a petition for postconviction relief, which was denied. No appeal was taken from that denial. Thereafter, Appellant filed a petition for writ of habeas corpus, which the circuit court denied. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal and the petition moot, holding (1) Appellant failed to demonstrate that his judgment was invalid on its face or that he was otherwise illegally detained; and (2) nothing in Appellant's other allegations would provide a basis on which a writ of habeas corpus could issue. View "Smith v. Hobbs" on Justia Law

Petitioner was found guilty by a jury of possession of a firearm by a felon as a result of his involvement in a shooting outside a nightclub. The court of appeals affirmed. Petitioner subsequently sought a writ of error coram nobis or certiorari so the trial court could consider a belated Ark. R. Crim. P. 37 petition on the question presented and for interpretation of new federal precedent found in Martinez v. Ryan and clarification of application to Arkansas law and procedure. The Supreme Court denied the petition, holding that Petitioner failed to state a ground on which a writ of error coram nobis or certiorari was warranted. View "Robinson v. State" on Justia Law

Pursuant to a negotiated plea agreement, Appellant pled guilty in 1997 in the Pope County circuit court to criminal charges. He was sentenced to 120 months' incarceration. In 2011, Appellant was again convicted of criminal charges, this time in Pike County Circuit Court. Later that year, the State filed a petition pursuant to the Inmate Reimbursement Act, seeking reimbursement of the costs of Appellant's incarceration. Funds were taken from Appellant's inmate account and placed in the Pope County circuit court's registry pending the outcome of the action. Appellant filed a motion to dismiss, and the State replied to the motion and filed a motion to transfer the action to the Pike County circuit court. The circuit court denied Appellant's motion to dismiss and granted the State's motion to transfer the action. Appellant sought an appeal and requested to proceed in forma pauperis. The Supreme Court denied the motion to proceed forma pauperis, as there was not a final, appealable order entered in this case, and it was clear Appellant could not prevail if the matter were allowed to proceed. View "Plunk v. State" on Justia Law

Appellant was convicted of battery in the third degree and sentenced to twelve months' probation. He was further ordered to pay costs and fees, as well as restitution of $40,304, "less any payments received through insurance claim and/or civil recovery from defendant." The State later filed a petition for revocation of Appellant's probation, alleging that, while Appellant's insurance had paid $29,595 toward the victim's civil claim, a balance of $10,709 remained, toward which Appellant had failed to make any payments. After a hearing, the circuit court extended Appellant's probation and directed him to make restitution of $10,709. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant had not fulfilled his restitution obligation. View "Moore v. State" on Justia Law

Pursuant to a negotiated plea agreement, Appellant pled guilty to manufacturing a controlled substance, two counts of possession of drug paraphernalia with the intent to manufacture methamphetamine, and failure to appear. Appellant subsequently filed a petition for writ of habeas corpus and a motion to proceed in forma pauperis. The circuit court granted the motion but denied the petition. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that because none of the allegations contained in Appellant's petition provided a basis for finding that a writ of habeas corpus should issue, it was clear Appellant could not prevail if his appeal were allowed to proceed. View "McHaney v. Hobbs" on Justia Law

Appellant lodged an appeal in the Supreme Court from an order of the circuit court that denied his petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. Appellant filed a motion to be provided a copy of the record and a motion to stay the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding (1) to the extent Appellant's claims were cognizable under Ark. R. Crim. P. 37.1, his request for relief was properly treated as a petition under Rule 37.1 and was subject to the time limitations associated with the rule; and (2) because Appellant's petition was not timely filed under either Rule 37.1 or section 16-90-111, the trial court did not err in concluding that the petition was not timely. View "Hickman v. State" on Justia Law

A jury convicted Appellant of possession of a controlled substance with intent to deliver methamphetamine and sentenced him to life imprisonment without parole. Appellant challenged his conviction on the basis that his right to effective counsel was violated by a conflict of interest and that the trial court abused its discretion in allowing evidence of gang affiliation during the sentencing hearing. The Supreme Court affirmed, holding (1) the Court was precluded from reviewing Appellant's ineffective assistance claim because he did not raise it at the trial court level; and (2) Appellant's claim that the trial court erred in admitting evidence of gang affiliation during the sentencing phase of the trial was also not preserved for appeal. View "Guevara v. State" on Justia Law

Appellant was convicted of four counts of capital murder and one count of kidnapping. On appeal, Appellant contended (1) the State's use of inconsistent prosecutorial theories in his trial and in the separate trial of a co-defendant denied him due process of law; and (2) because the police failed to inform him that he was under no legal obligation to comply with their request to speak with them, Ark. R. Crim. P. 2.3 was violated and any subsequent statements to police should have been suppressed. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's motion to prohibit the prosecution from arguing contradictory theories of the case; and (2) the circuit court's denial of Appellant's motion to suppress his statements was not clearly against the preponderance of the evidence. View "Green v. State" on Justia Law