Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant Johnny Tarkington was found guilty of aggravated robbery and sentenced, as a habitual offender, to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, making several allegations of error and claiming actual innocence. The circuit court denied Appellant's petition, finding (1) Appellant failed to establish the circuit court's lack of jurisdiction or that his commitment order was facially invalid, and (2) Appellant did not establish a claim of actual innocence based upon scientific evidence that was unavailable at the time of his trial. The Supreme Court affirmed, holding that Appellant's claims were not cognizable for a writ of habeas corpus to issue. View "Tarkington v. Norris" on Justia Law

Appellant Steven Samples entered into a negotiated plea of guilty to six drug-related charges and was sentenced to 300 months' imprisonment. On December 2, 2009, a judgment-and-commitment order was entered reflecting Appellant's negotiated plea. On December 20, 2010, Appellant filed a motion to correct clerical mistake in his commitment order, asserting that that the date reflected on the judgment did not conform with the agreement he reached in pleading guilty. The circuit court treated Appellant's motion as one seeking postconviction relief and denied the motion. The Supreme Court dismissed the appeal, holding (1) the court properly treated Appellant's motion as one seeking postconviction relief because it sought to correct a judgment that was based on a substantive claim; and (2) the court lacked jurisdiction to consider Appellant's motion because Appellant's postconviction motion to correct was untimely filed. View "Samples v. State" on Justia Law

Following a jury trial, Appellant Julian Rueda was convicted of three drug-related offenses and was sentenced to a total of 600 months' imprisonment. The court of appeals affirmed his convictions and sentence. Appellant subsequently filed a pro se petition for postconviction relief, asserting ten claims all alleging that trial counsel was ineffective. The trial court denied each of the allegations made by Appellant in his petition. In his appeal, Appellant contended that the circuit court erred in finding that his trial counsel did not render ineffective assistance in failing to file a motion to dismiss based on a speedy-trial violation. The Supreme Court affirmed, holding that because any motion to dismiss based on speedy trial would have lacked merit, trial counsel was not ineffective for failing to make such a motion, and for this reason, the circuit court did not clearly err in its judgment. View "Rueda v. State" on Justia Law

After a jury trial, Appellants Michael Myers and Scott Hall were convicted of several drug-related crimes. Appellants' convictions were affirmed by the court of appeals. Appellants subsequently filed petitions for postconviction relief, alleging ineffective assistance of counsel. The trial court entered orders denying postconviction relief as to both Appellants. The Supreme Court affirmed the denial of postconviction relief, holding that Appellants failed to meet their burden under Washington v. Strickland by failing to demonstrate that their counsel was deficient or that, if counsel was deficient, there was a reasonable probability that, but for counsel's errors, the fact-finder would have had a reasonable doubt respecting guilt. View "Myers v. State" on Justia Law

Appellant Corey Lambert was convicted on charges of attempted murder in the first degree, aggravated robbery, and theft of property. The court of appeals affirmed Appellant's convictions. Appellant subsequently filed a petition for postconviction relief, stating four grounds for relief in his petition. All of Appellant's stated grounds alleged ineffective assistance of counsel in connection with the State's failure to introduce certain physical evidence during Appellant's jury trial. The trial court denied the petition. Appellant appealed, and before the Supreme Court was a motion Appellant filed related to his appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant's petition was clearly without merit, as Appellant failed to demonstrate that counsel might have raised a successful challenge to the disputed evidence, and none of Appellant's grounds for relief demonstrated prejudice. View "Lambert v. State" on Justia Law

Appellant Carlos Keck was convicted of rape and sentenced to twenty-five years' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, asserting that his trial counsel was ineffective for not objecting or making an attempt to limit expert testimony that Appellant alleged improperly bolstered the victim's testimony. The trial court denied the petition. The Supreme Court affirmed, holding that trial counsel's performance did not fall below an objective standard of reasonableness under the first prong of Washington v. Strickland, and therefore, the trial court did not err in finding that counsel's performance was not ineffective. View "Keck v. State" on Justia Law

Appellant Phillip Harrison was convicted of two counts of theft of property. Appellant subsequently filed a pro se petition for postconviction relief. The trial court denied the petition, finding that it was not timely filed, but provided a ruling on two issues raised in the petition, despite that finding. Appellant appealed, and before the Supreme Court were several motions related to the appeal. The Court dismissed the appeal and declared the motions moot, holding (1) the trial court erred in reaching issues not related to whether the petition met the procedural requisites of the Court's rules; and (2) the trial court correctly denied relief on the petition because no relief could be granted on an untimely petition. View "Harrison v. State" on Justia Law

Appellant Damont Ewells, who was incarcerated, filed a civil complaint against Appellees, three law enforcement officers, seeking compensatory and punitive damages and injunctive relief. In his complaint, Appellant alleged that Appellees violated his constitutional rights, specifically claiming due process and excessive force violations. The circuit court granted Appellees' motion for summary judgment and dismissed Appellant's complaint with prejudice. The Supreme Court affirmed, holding that Appellant, as the opposing party, failed to meet proof with proof and to demonstrate the existence of a genuine issue of material fact, and therefore, the circuit court properly granted summary judgment in favor of Appellees. View "Ewells v. Constant" on Justia Law

William Eubanks was convicted of rape and sentenced to life imprisonment. Eubanks subsequently filed a petition for postconviction relief, asserting that his trial counsel was ineffective for failing to challenge his prosecution based on speedy trial and for failing to mount a constitutional challenge to the pedophile exception recognized by the Supreme Court under Ark. R. Evid. 404(b). The Court affirmed, holding (1) there was no violation of Eubanks' right to a speedy trial, and therefore, Eubanks' trial counsel was not ineffective for failure to assert a violation of Eubanks' right to a speedy trial; and (2) the failure of counsel to make a constitutional challenge to the established evidentiary rule of allowing for a pedophile exception in admission of evidence did not constitute an error so serious to rise to the level of ineffective assistance of counsel. View "Eubanks v. State" on Justia Law

After a jury trial, Appellant Lesa Menne was found guilty of possession of drug paraphernalia with the intent to use, and possession of marijuana. On appeal, Menne challenged the circuit court's denial of her motion to suppress evidence recovered in a search of her vehicle after she was stopped by a law enforcement officer for a traffic violation. The Supreme Court affirmed the circuit court's ruling, holding that the circuit court correctly found that a number of factors gave the officer a reasonable suspicion during the course of the traffic stop that Menne was committing, had committed, or was about it commit a crime involving danger to persons or property, and that reasonable suspicion was a sufficient basis to detain Menne further. View "Menne v. State" on Justia Law