Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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Appellant Cameka Sullivan was convicted of permitting the abuse of her minor child and hindering the apprehension or prosecution of her child's abuser and sentenced to a cumulative sentence of 216 months' imprisonment. The court of appeals affirmed her convictions. The Supreme Court vacated the decision of the court of appeals and affirmed the circuit court's judgment, holding that the circuit court (1) correctly concluded that Appellant's right to a speedy trial was not violated; (2) did not err in denying Appellant's motion for directed verdict of acquittal on the charge of hindering the apprehension of her child's abuser; and (3) did not abuse its discretion in allowing certain challenged testimony. View "Sullivan v. State" on Justia Law

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S.L. was charged with one count of rape in the juvenile division of the circuit court. Before the adjudication hearing, S.L. filed a motion to dismiss for violation of his right to a speedy trial, which the circuit court denied. S.L. then filed another motion to dismiss for lack of a speedy trial, which the circuit court granted. The State appealed. After noting that the State's appeal under these circumstances required the Supreme Court's review for the correct and uniform administration of the criminal law under Ark. R. App. P.-Crim. 3(d) instead of relying on facts unique to the case, the Court dismissed the appeal, as it did not have at issue the correct and uniform administration of justice and, instead, involved the application of the Court's speedy-trial rules to the unique facts of the case. View "State v. S.L." on Justia Law

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Appellant was found guilty by a jury of capital murder and sentenced to death. In subsequent proceedings under Ark. R. Crim. P. 37.5, the trial court granted Appellant a new sentencing hearing based upon trial counsel's failure to object to evidence that was presented as an aggravating circumstance. On resentencing, Appellant was sentenced to life imprisonment without parole. Appellant thereafter filed a pro se petition for writ of habeas corpus, which the circuit court denied. Appellant appealed. Before the Supreme Court were Appellant's motions related to the appeal. The Court dismissed the appeal and declared the motions moot, holding that Appellant did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Fudge v. Hobbs" on Justia Law

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James Wedgeworth was convicted of capital murder and sentenced to life without parole. The Supreme Court affirmed the conviction and sentence entered in this case, holding (1) Wedgeworth's argument that the circuit court erred in overruling a hearsay objection when the victim's father testified that the victim came to him for help because "there were threats against her life" was not preserved for review on appeal; (2) while the circuit court erred in admitting the victim' writings contained in a spiral notebook, Wedgeworth did not demonstrate that he was prejudiced by the admission of the evidence; and (3) there was no error in admission of certain photographs of the victim, and therefore, the circuit court did not err by failing sua sponte to exclude the photographs under Wicks v. State. View "Wedgeworth v. State" on Justia Law

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Appellant Vincent Webb was convicted of the kidnapping and rape of a twelve-year-old girl and was sentenced as a habitual offender to concurrent sentences of forty years and life imprisonment. Appellant appealed, contending that the circuit court erred by refusing his request to instruct the jury that second-degree sexual assault was a lesser-included offense of rape. The Supreme Court affirmed the circuit court's refusal of Appellant's proffered jury instruction, holding that, consistent with Joyner v. State, the circuit court correctly determined that second-degree sexual assault requires proof of additional elements that rape does not, and therefore, it is not a lesser offense included in rape. View "Webb v. State" on Justia Law

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Petitioner Timothy Davis entered a plea of guilty to capital murder and was sentenced to life imprisonment without parole. Davis subsequently filed a petition for postconviction relief, which the trial court denied on its merits. Petitioner did not perfect an appeal from the trial court's order denying relief and sought leave from the Supreme Court to proceed with a belated appeal. The Court denied the motion, holding that because Petitioner's only ground for granting a belated appeal was that he timely filed a notice of appeal and he did not substantiate that claim, Petitioner failed to demonstrate that he should be permitted to proceed with a belated appeal of the trial court's order. View "Timothy. v. State" on Justia Law

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Appellant Terrell Davis pleaded guilty to multiple felony offenses. Ninety-five days after the judgments were entered-of-record, Appellant filed in the trial court a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition was denied on the ground that it was not timely filed under the rule. Appellant appealed. Before the Supreme Court was a motion filed by Appellant related to his appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant's petition was untimely pursuant to Ark. R. Crim. P. 37.2(c), which provides that a petition under the rule must be filed within ninety days of the date the judgment was entered if the petitioner entered a plea of guilty. View "Terrell v. State" on Justia Law

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In two separate cases, Appellant Brian Heard entered negotiated pleas to a total of four counts of delivery of a controlled substance as to various drugs and that eleven other charges were nolle prossed. Appellant timely filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, which the trial court denied. Appellant appealed, contending that his guilty plea was coerced by trial counsel and that trial counsel was ineffective. The Supreme Court affirmed, holding (1) Appellant did not provide credible evidence to support his claim that he was coerced and would not have entered a guilty plea had counsel provided effective assistance; and (2) Appellant did not meet his burden to show prejudice from any deficient performance on the part of trial counsel. View "Heard v. State" on Justia Law

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Petitioner Belynda Goff was found guilty by a jury of first-degree murder in the death of her husband and was sentenced to life imprisonment. Petitioner subsequently requested that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In support of her petition, Petitioner contended that her defense at the time of trial was not made aware of three documents Petitioner recently discovered. Petitioner argued that the documents offered proof that someone else murdered her husband and that the State violated the requirements of Brady v. Maryland by withholding the documents from the defense. The Supreme Court denied the writ, holding that Petitioner did not show there was a reasonable probability that the outcome of the trial would have been different had any of the documents at issue been available to the defense. View "Goff v. State" on Justia Law

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Appellant Tyrone Ellis was convicted of first-degree murder and felon in possession of a firearm and was sentenced to life in prison. Ellis appealed, contending (1) the evidence was insufficient to support his conviction, and (2) the prosecuting attorney improperly inquired into the nature of Ellis's prior felony convictions during cross-examination. The Supreme Court affirmed the convictions, holding (1) viewing the evidence on appeal in the light most favorable to the State, there was substantial evidence to support Ellis's conviction for first-degree murder and felon in possession of a firearm; and (2) the trial court did not abuse its discretion by allowing into admission Ellis's prior crimes for impeachment purposes where it was clear from the record that the probative value of the evidence outweighed the potential for unfair prejudice. View "Ellis v. State" on Justia Law