Justia Arkansas Supreme Court Opinion Summaries

Petitioner Steven Pinder was found guilty of two counts of rape and was sentenced to life imprisonment. Petitioner subsequently filed a petition with the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecutor withheld certain evidence from the defense during trial in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that all of the claims raised by Petitioner were known to him at trial, were not in existence at the time of trial, had not been diligently advanced, or were otherwise noncognizable.

Appellant Jeff Morgan was found guilty by a jury of kidnapping, a Class Y felony, and second-degree battery and was sentenced as a habitual offender to an aggregate term of life imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus. The petition was denied without a hearing. Appellant appealed and filed a motion seeking photocopies of his brief-in-chief at public expense. The Supreme Court dismissed the appeal and declared the motion moot, holding that the circuit court did not err in denying the relief sought because Appellant's petition did not state a basis to warrant issuance of the writ.

A jury found Appellant Terry Matthews guilty of aggravated robbery. Appellant subsequently filed a petition for postconviction relief, arguing ineffective assistance of counsel at trial. The circuit court denied the petition. The Supreme Court affirmed, holding, inter alia, that (1) counsel was not ineffective for failing to raise a speedy-trial argument because Appellant was not denied the right to a speedy trial; (2) counsel was not ineffective by not objecting to testimony regarding Appellant's history of drug and alcohol abuse because counsel's decision was the product of reasonable professional judgment; and (3) counsel was not ineffective for failing to object during closing argument because Appellant did not establish that he was denied a fair trial by the failure to object.

Appellant James Lowe entered a plea of no contest to a charge of first-degree sexual abuse. More than a decade later, Appellant pled guilty to a charge of failing to register as a sex offender. Appellant subsequently filed a petition for writ of habeas corpus, arguing (1) his sentence in the sexual-abuse case was illegal because it exceeded the maximum sentence allowed, and there was a speedy-trial violation; and (2) his sentence in the failure-to-register case was a direct result of the first illegal sentence and, thus, was also illegal. The circuit court denied Appellant's petition, finding that he failed to demonstrate a basis for habeas relief. The Supreme Court affirmed, holding that Appellant could not demonstrate that he was being illegally detained as a result of his sentence in the sexual-abuse case because (1) he completed his sentence before he filed his habeas petition, and (2) petitioners cannot obtain habeas relief from a sentence that has already been served in full.

A jury convicted Appellant Melvin Lockhart of first-degree murder and theft of property. The court of appeals affirmed, holding that because Appellant did not move for a directed verdict on the offense of first-degree felony murder, the court was precluded from reaching the issue of sufficiency of the evidence. Appellant subsequently filed a motion for postconviction relief, alleging, among other things, that his trial counsel was ineffective for failing to move for a directed verdict. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding the circuit court properly denied Appellant's petition where (1) Appellant did not demonstrate that he was prejudiced by trial counsel's error in failing to make a directed-verdict motion; and (2) Appellant failed to show that trial counsel prejudiced the defense with respect to Appellant's not testifying at trial.

Appellant Gregory Holt was convicted of aggravated residential burglary and first-degree domestic burglary. Appellant was sentenced to life imprisonment on the aggravated residential burglary charge and forty years on the first-degree domestic battery charge, with the sentences to run concurrently. The Supreme Court affirmed, holding (1) the circuit court correctly denied Appellant's directed-verdict motion as there was sufficient evidence to support his aggravated residential burglary conviction; (2) the circuit court did not abuse its discretion in permitting Appellant to be shackled in front of the jury as the restraints were reasonably necessary to maintain order and security in the courtroom; and (3) Appellant's remaining arguments were not preserved for appellate review.

Appellant Lamarcus Christopher entered a plea of guilty to various drug offenses. Six months later, Appellant pled guilty to possession of a firearm by certain persons. More than a year later, the circuit court entered two amended judgments on each of the two cases, altering only the name of the offenses to include that Appellant was charged "as habitual." Appellant's sentences were not altered in either amendment. Appellant subsequently filed a pro se petition for writ of habeas corpus, arguing (1) he had not been properly notified that he was being charged as a habitual offender, (2) the amended judgment conflicted with the sentence as ordered in open court where he was not pronounced a habitual offender, and (3) but for this misrepresentation, he would not have pled guilty to the charges. The circuit court denied Appellant's petition with prejudice. The Supreme Court affirmed, holding that the circuit court was correct to deny Appellant's petition because he made neither a claim that his judgment-and-commitment order was invalid on its face nor a claim that the sentencing court was without jurisdiction.

Appellant Ke'ondra Chestang, an inmate incarcerated in the Arkansas Department of Correction (ADC) at a facility in Lincoln County, filed a petition for writ of habeas corpus in the Lincoln County circuit court. The circuit court denied the petition. Appellant then filed motions seeking an order directing the circuit clerk in Lincoln County to provide him with certain documents and an extension of time in which to file his brief. At that point Appellant had been transferred to an ADC facility located in Jefferson County. The Supreme Court dismissed Appellant's appeal and declared the motions moot, holding that because Appellant was in Jefferson County when he filed the motions, the Lincoln County circuit court could no longer grant the relief requested by Appellant because it did not have jurisdiction.

After a jury trial, Appellant Marcus Atkins was convicted of first-degree battery, kidnapping, and possession of a firearm by certain persons. Appellant filed a pro se petition for postconviction relief, arguing that he was not afforded effective assistance of counsel because his trial counsel failed to object when the trial judge sentenced him to a firearm enhancement rather than submitting the issue to a jury. After holding a joint hearing on the petitions filed by Appellant and two codefendants, the trial court denied relief. The Supreme Court subsequently dismissed the appeal of one of Appellant's codefendants from the same circuit court order. The Supreme Court then affirmed the denial of Appellant's petition, holding (1) Appellant's petition and the arguments he made on appeal were virtually identical to those made by his codefendant; and (2) for the reasoning explained in the appeal of the codefendant, the circuit court did not err in denying Appellant's petition.

Appellant Vera Arnold was convicted of criminal solicitation to commit capital murder and criminal conspiracy to commit theft by deception. After she was paroled, Appellant filed petitions to seal the records of both convictions pursuant to Ark. Code Ann. 5-4-105(a)(2) and Ark. Code Ann. 16-93-1201 to -1210. The circuit court denied the petitions. Appellant subsequently filed new petitions to seal the records of her convictions, asserting she had been sentenced under Ark. Code Ann. 5-4-105(a)(1) and Ark Code Ann. 16-93-301 to -303. Along with the petitions, Appellant filed a motion for relief from the circuit court's previous order, arguing (1) because sections 16-93-1201 to -1210 were not in effect as of the date of her offenses, she was eligible to refile her petitions under sections 16-93-301 to -303; and (2) sections 16-93-301 to -303 were unconstitutional. The circuit court denied the petitions and the motion. The Supreme Court affirmed, holding (1) the trial court did not err in applying rational-basis review to the statutes in question; (2) the trial court did not err in finding the statutes in question constitutional; and (3) the statutes in question did not violate Appellant's constitutional right to a legal sentence.