Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Civil Rights
Simmons v. State
Appellant Joe Simmons was convicted on drug-related charges and failure to appear. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition. Appellant appealed, contending that the trial court erred in finding that trial counsel was not ineffective for failing to object to the restraints used on Appellant during his jury trial or for failing to request an instruction ordering the jury not to consider those restraints in their deliberations. The Supreme Court affirmed, holding that there was no clear error in the trial court's findings and its conclusion that trial counsel was not ineffective.
Reed v. Hobbs
Appellant Anthony Reed was found guilty by a jury of aggravated robbery, theft of property, and two counts of second-degree battery. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus. The circuit court dismissed the petition. Appellant appealed. Before the Supreme Court was Appellant's motion to correct the record. The Court dismissed the appeal and declared the motion moot, holding that Appellant could not prevail on appeal of the order denying his petition where he failed to state cognizable claims and did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue.
Meadows v. State
Following a jury trial, Appellant Vadarian Meadows was found guilty of capital murder, residential burglary, and theft of property. For reversal, Appellant contended (1) the evidence was not sufficient to support his convictions because the State failed to corroborate his confession and the testimony of an accomplice, and (2) the capital murder and first-degree murder statutes were unconstitutionally vague because they were substantially identical and resulted in jury confusion. The Supreme Court affirmed, holding (1) because the evidence showed that the corroboration requirements were met, there was substantial evidence to support Appellant's convictions; and (2) Appellant's second contention was not preserved for appeal.
Abernathy v. State
Appellant Routy Abernathy was convicted of two counts of rape. Appellant subsequently filed a pro se petition for postconviction relief, raising a number of claims of ineffective assistance of counsel. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in finding (1) trial counsel did not err by failing to investigate, consult with, or call a medical expert; (2) Appellant was not prejudiced from counsel's remarks during his opening statement; (3) Appellant did not demonstrate that he was sufficiently prejudiced by counsel's error in failing to object to a witness's testimony that she believed one victim's allegations to meet his burden of proof; and (4) a victim's claims about sexual abuse by her grandfather would not have been admissible and, therefore, counsel was not ineffective for failing to seek a ruling on introduction of the evidence.
Tolliver v. State
Appellant Darcel Tolliver entered in the circuit court a plea of guilty to multiple felony offenses. Appellant was sentenced as a habitual offender to 240 months' imprisonment. Appellant subsequently filed a pro se petition pursuant to Ark. Code Ann. 16-90-111, contending that he was entitled to a reduction in sentence. The petition was dismissed on the ground that it was not timely filed. Appellant appealed and filed motions related to that appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that the trial court did not err when it dismissed Appellant's petition because Appellant did not timely file his petition for postconviction relief.
Strain v. State
Appellant Ricky Strain was convicted by a jury of first-degree murder and was sentenced to 300 months' incarceration. Appellant subsequently filed a timely petition for postconviction relief, which the trial court denied following an evidentiary hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective for failing (1) to preserve the sufficiency-of-the-evidence issue for appeal where Appellant's conviction was supported by substantial evidence, (2) to seek certain jury instructions regarding accomplice liability, (3) to seek severance of Appellant's trial from his codefendant's trial, and (4) to properly argue that a witness's prior inconsistent statement could not be considered by the jury for the truth of the matter stated, as Appellant failed to demonstrate that any objection to the statement or request for a limiting instruction would have been meritorious.
Pinder v. State
After a jury trial, Petitioner Steven Pinder was found guilty of two counts of rape and sentenced to life imprisonment. The Supreme Court affirmed. Petitioner subsequently filed a petition in the Supreme Court seeking to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, which the Court denied. Before the Court was Petitioner's motion for reconsideration. The Court denied the motion, holding that Petitioner failed to establish that the Court should reconsider its denial of his petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis where Petitioner failed to establish that the Court's denial of his petition was based on an erroneous statement of fact or conclusion of law.
Menne v. State
After Lesa Menne was stopped for a traffic violation, a law enforcement officer searched her vehicle and discovered illegal drugs. Menne was charged with possession of marijuana, possession of drug paraphernalia, and possession of methamphetamine. Menne moved to suppress the items seized on grounds that the search was illegal. The circuit court denied the motion. After the subsequent jury trial, Menne was found guilty of the charges. Menne appealed, challenging the circuit court's denial of her motion to suppress. The court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the judgment of the circuit court, holding that the circuit court's ruling denying Menne's motion to suppress the evidence seized as a result of the officer's search of her vehicle was not clearly against the preponderance of the evidence.
Martin v. State
Petitioner Lawrence Martin was convicted of capital murder. The Supreme Court affirmed. Petitioner subsequently petitioned the Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, listing three bases for the writ in his petition. Petitioner also filed motions relating to the petition. The Supreme Court denied the petition and declared the motions moot, holding that Petitioner's claims were largely based upon trial error, rather than hidden or unknown facts, which claims were not cognizable in a coram-nobis proceeding. Therefore, Petitioner failed to meet his burden to show that the writ was warranted.
Jones v. State
After a jury trial, Appellant Rodney Jones was convicted of capital murder in the shooting death of his ex-wife. The jury sentenced Appellant to life imprisonment without parole. The Supreme Court affirmed the conviction and sentence, holding (1) certain statements made by the State during closing arguments were not so inflammatory that justice could not be served by continuing the trial, and the circuit court did not abuse its discretion in denying Appellant's motion for a mistrial; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offenses of reckless manslaughter and negligent homicide.