Justia Arkansas Supreme Court Opinion Summaries

Appellee Kenneth Harrison was tried and convicted of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed. Harrison subsequently filed a petition for postconviction relief. The circuit court entered an order granting a new trial based on its finding that trial counsel was ineffective for failing to discover the juvenile adjudication for capital murder of one of the two eyewitnesses who testified to Harrison's murder of the victim, and for failing to use that conviction to impeach the witness at trial or to investigate the witness's background and develop a strategy of defense implicating the witness as the perpetrator of the victim's murder. The State appealed. The Supreme Court affirmed, holding that the circuit court's findings were not clearly erroneous, and therefore, the court did not err in granting postconviction relief. View "State v. Harrison" on Justia Law

Appellant Avery Scott entered a plea of guilty to sexual assault in the second degree and was sentenced to a term of 180 months' imprisonment. Scott subsequently filed a motion to withdraw his plea, arguing that his plea was involuntary because his attorney pressured him to accept it. The motion was denied. Scott then filed a petition for postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding the circuit court did not err in denying the petition where (1) Scott's argument that the trial court did not have jurisdiction to convict and sentence him was without merit; (2) Scott's claim that the prosecutor acted in bad faith was not cognizable in a postconviction relief petition; and (3) trial counsel did not afford Scott ineffective assistance of counsel. View "Scott v. State" on Justia Law

Appellant Broderick Laswell was found guilty of capital murder and aggravated robbery and was sentenced as a habitual offender to life imprisonment without parole plus 720 months' imprisonment, respectively. Appellant appealed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion by (1) denying Appellant's motions for directed verdict, as there was substantial evidence to support the jury's verdict that Appellant committed aggravated robbery and capital murder; (2) admitting certain character evidence over Appellant's objection; (3) admitting certain crime-scene evidence over Appellant's chain-of-custody objections; and (4) excluding certain expert testimony during the guilt phase of trial. View "Laswell v. State" on Justia Law

Appellant Jessie Hill was convicted of capital murder. Appellant subsequently filed a motion to vacate judgment under Act 1780, seeking a hearing to establish a scientific predicate for a new trial, the production of a report for the results of latent-fingerprint analysis that Appellant alleged the State performed on a marble rolling pin, and additional testing of evidence from his trial. The trial court denied the motion, and Appellant appealed. Before the Supreme Court were Appellant's motion to compel, requesting that the Supreme Court order production of the same latent-print report, and petition for writ of mandamus to the state attorney general to enforce the order that he sought in his motion. The Court dismissed the appeal and declared the motion and petition moot, holding that Appellant's petition was properly dismissed, as his motion for relief did not establish that he was entitled to seek relief under Act 1780 or that the trial court could assume jurisdiction. View "Hill v. State" on Justia Law

Appellant Kenneth Barrow was found guilty of sexual indecency with a child, second-degree sexual assault, rape, and first-degree terroristic threatening. The court of appeals affirmed. Barrow filed an amended petition for postconviction relief, which the circuit court dismissed without prejudice for failing to comply with the requirements of Ark. R. Crim. P. 37.1(b). The court then gave Barrow ten days to file a compliant petition. Barrow subsequently filed a second amended petition for postconviction relief within the ten-day period, alleging ineffective assistance of counsel. The circuit court denied the petition, concluding that Barrow's counsel was not ineffective and that the court lacked jurisdiction to hear the matter because the second amended petition was not filed until after the sixty-day time period provided under Rule 37.1. The Supreme Court reversed, holding (1) under the facts of this case, the circuit court had jurisdiction to hear Barrow's amended petition; and (2) the court's order finding that Barrow did not meet his burden of proof by showing that his counsel was ineffective was conclusory in nature and failed to comply with Ark. R. Crim. P. 37.3(c). Remanded. View "Barrow v. State" on Justia Law

On October 12, 1993, Appellee Harris Martin was found guilty of negligent homicide and sentenced to five years probation. On April 9, 2009, Martin filed a petition to seal the record of his negligent-homicide conviction. The circuit court granted the petition, noting Ark. Code Ann. 5-10-105 as the court's authority for the expungement. The State appealed. The Supreme Court reversed, holding that the circuit court erred by sealing Appellant's negligent-homicide conviction pursuant to section 5-10-105, as the statute lacked any provision for expungement of Appellant's record, and therefore, the circuit court's order did not provide a proper basis for expungement. View "State v. Martin" on Justia Law

Petitioner Charles Rodgers was convicted of rape and sentenced to life imprisonment. Petitioner subsequently filed a petition in the Supreme Court that sought to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and two motions that sought to supplement and amend that request with a substituted petition or additional documents. The Supreme Court denied the requests to supplement and amend the petition and the petition to reinvest jurisdiction in the trial court, holding that Petitioner did not meet his burden to state some basis that would warrant a proceeding for the writ. View "Rodgers v. State" on Justia Law

Appellant Ronald Little pled no contest to one charge of manslaughter and one charge of second-degree battery, for which he received a cumulative sentence of 240 months' incarceration. Appellant subsequently filed a verified pro se petition for postconviction relief, alleging that his trial counsel was ineffective for several reasons. Before the Supreme Court were two pro se motions filed by Appellant related to his appeal. The Supreme Court dismissed Appellant's appeal and declared the motions moot, holding that the circuit court did not clearly err in concluding that counsel's performance was not ineffective, and therefore, Appellant could not prevail if his appeal were allowed to proceed. View "Little v. State" on Justia Law

Appellant Jessie Goins was convicted by a jury of aggravated robbery and was sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a petition for writ of habeas corpus. The petition was denied by a written order. Appellant then filed a second petition for writ of habeas corpus, asserting the same grounds for the writ as he alleged in the earlier habeas petition. The petition was denied. The Supreme Court affirmed, holding (1) the circuit court did not err in determining that the claims presented in Appellant's petition were not the kind that could support habeas-corpus relief; and (2) the circuit court did not err in determining that Appellant's second point was not cognizable in a habeas-corpus petition. View "Goins v. Norris" on Justia Law

Appellant Cornelius Earl was convicted on three counts of delivery of a controlled substance and was sentenced to a total of 960 months' imprisonment. The court of appeals affirmed his convictions and sentence. Earl subsequently filed a petition for postconviction relief, alleging that his trial counsel operated under an actual conflict of interest due to counsel's simultaneous representation of Earl and his girlfriend, who also faced charges stemming from the same incident. Earl alternatively asserted that any waiver by him of the conflict was not knowing, voluntary, or intelligent. The circuit court denied the petition. Earl appealed, arguing that the trial court did not meaningfully inquire into the propriety of multiple representation. The Supreme Court affirmed, holding that because nothing in the circumstances of this case indicated that the trial court had a duty to inquire whether there was a conflict of interest, the inquiry was not insufficient, and therefore, the circuit court did not err in denying postconviction relief. View "Earl v. State" on Justia Law