Justia Arkansas Supreme Court Opinion Summaries

Appellant was serving terms on three sentences for three convictions when he filed a pro se petition for writ of habeas corpus. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding (1) the circuit court did not err by not conducing a hearing on Appellant's petition because Appellant failed to demonstrate probable cause for the issuance of the writ; (2) the circuit court committed no error if it did not make written findings to support its decision; (3) Appellant's claim that his conviction for delivery of a controlled substance was invalid stated no grounds upon which the writ could properly issue and therefore failed; and (4) any challenges to Appellant's convictions for second-degree escape were moot because the sentences he received for those offenses expired.

Appellant Justin Anderson was tried, convicted, and sentenced to death for the murder of an elderly woman. Anderson filed a petition for postconviction relief, claiming ineffective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding (1) (a) Anderson did not overcome the presumption that trial counsel's handling of the issue of Anderson's mental retardation was the result of reasonable professional judgment, (b) the fact that a doctor who participated in the issue of Anderson's mental retardation was later discredited did not warrant a remand, and (c) Anderson was not allowed to revisit the issue of conflicting expert evidence regarding Anderson's mental retardation and mental health presented at his trial; (2) Anderson failed to demonstrate that he was prejudiced by the admission of statements Anderson to police and counsel's failure to challenge aspects of the statements in relation to his mental retardation; and (3) the circuit court did not err in ruling that no mental impairment on the part of defense counsel had been proven.

Sherman Watson, who was previously convicted on a criminal matter, filed a pro se petition for postconviction relief. The circuit court denied the petition, finding it did not have jurisdiction because the petition was not timely filed. The Supreme Court twice remanded for findings of fact as to the date of tender of the petition. On the second remand, the trial court once again failed to make specific findings as to the date that the petition was first tendered to the clerk and rejected. For the third time, the Supreme Court again remanded for findings of fact on the date of tender to the circuit clerk of Appellant's petition, holding that the circuit court's order did not provide an answer to the specific question of what date or dates petitions were tendered to the circuit clerk.

Appellant Reginald Richardson was convicted of possession of cocaine with intent to deliver. Because the offense was committed within 1000 feet of a public-housing facility, Appellant's sentence was enhanced pursuant to Ark. Code Ann. 5-64-411(a)(4). The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, which the circuit court denied without a hearing. The Supreme Court affirmed, holding (1) the trial court's decision to render its order without a hearing was not clearly erroneous as the record showed Appellant's allegations to be without merit; (2) any error on the part of Appellant's counsel to object to a wording error contained in one verdict form was harmless, and Appellant failed to prove prejudice; and (3) trial counsel was not effective for failing to object to the circuit court's failure to arraign him on the enhanced charge because Appellant waived formal arraignment and was not prejudiced by the lack of a formal arraignment on the enhancement.

Appellant William Hale was convicted of internet stalking and was sentenced to 276 months' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, asserting several instances of ineffective assistance of counsel and prosecutor misconduct. The circuit court denied Appellant's petition. The Supreme Court affirmed the order of the circuit court, holding (1) Appellant's series of allegations of ineffective assistance of counsel were entirely conclusory in nature in that there was no factual substantiation to demonstrate how Appellant's counsel specifically prejudiced the defense; and (2) Appellant's claims of prosecutorial misconduct were not cognizable in a petition for postconviction relief.

Appellant Michael Gilliland was convicted for rape and sexual assault. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, which the circuit court denied. At issue on appeal was whether Appellant filed his petition within sixty days of the date that the mandate issued in accordance with Ark. R. Crim. P. 37.2(c). The Supreme Court (1) remanded the case for findings of fact concerning the date of tender of the petition as the Court could not ascertain the actual date of tender of the petition in this case; and (2) declared the State's motion for extension of time to file its brief in conjunction with its motion to dismiss moot.

Appellant, a legal, permanent resident of the United States, pled guilty to one count of maintaining a drug premise. Later, Appellant was placed in a removal proceeding in immigration court. Appellant filed a petition for writ of error coram nobis, asserting that his trial counsel never informed him of the possible adverse immigration consequences that could result if he pled guilty to the charge. The circuit court denied Appellant's petition, finding that his ineffective assistance of counsel claim could have been raised in a petition for postconviction relief and did not provide a basis for coram-nobis relief. The Supreme Court affirmed, holding that Appellant's claim of ineffective assistance of counsel was not cognizable in a coram-nobis proceeding.

Petitioner Sanders Carter was convicted on charges of rape, aggravated robbery, and burglary. Petitioner unsuccessfully challenged that conviction through a number of different proceedings for various postconviction remedies, which failed. In the instant action, Petitioner brought a Petition before the Supreme Court requesting that it reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, asserting that evidence was withheld from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) if the evidence in this case was mislabeled as asserted, Petitioner had identified a hidden error of fact that may be cognizable in a proceeding for he writ, but (2) Petitioner did not demonstrate that the error would have been sufficient to prevent rendition of the judgment.

Appellant Matthew Barnett, an inmate incarcerated in a Department of Correction facility in Lee County, filed a pro se petition for writ of habeas corpus in the Lee County circuit court. The court denied the petition. Appellant appealed. Before the Supreme Court was Appellant's motion for leave to file a supplemental reply brief on appeal. After the motion was filed, Appellant was released from custody and was living in Pulaski County. The Supreme Court dismissed the appeal and declared the motion moot because Appellant was no longer within the jurisdiction of the circuit court in which he filed his petition.

Appellant Joseph Akin entered a negotiated guilty plea to a charge of possession of a controlled substance with intent to deliver. Appellant filed a petition for postconviction relief, alleging that he did not enter the guilty plea voluntarily. After a hearing, the trial court denied the motion. On appeal, Appellant contended that the circuit court's erroneous denial of his motion to suppress contraband discovered during a search after a traffic stop placed him in an untenable position that compelled him to plead guilty, thereby rendering his plea involuntary. The Supreme Court affirmed the trial court, holding that Appellant's argument was without merit.