Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a conditional plea of guilty to a charge of driving while intoxicated, sixth offense. Appellant appealed, arguing that his conviction violated the ex post facto clauses of the Arkansas Constitution and United States Constitution. This appeal presented an issue of first impression whether an appeal was allowed from Appellant’s conditional plea. The Supreme Court affirmed, holding (1) under the circumstances of this case, the Court has jurisdiction to consider the appeal; and (2) as to the merits, Appellant’s conviction does not violate the ex post facto clauses of the United States Constitution and Arkansas Constitution. View "Laymon v. State" on Justia Law

Appellant entered a guilty plea to first-degree murder and aggravated robbery and was sentenced to an aggregate sentence of 720 months’ imprisonment. Appellant later filed a petition for a writ of habeas corpus claiming that his sentence was illegal because it violated constitutional protections against double jeopardy. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not establish probable cause that he was illegally detained because he did not state facts in the petition to support his claim that the first-degree murder charge and the aggravated robbery charge were overlapping charges that violated double jeopardy. View "Holly v. Hobbs" on Justia Law

Plaintiff, a construction company, filed this suit after the Arkansas State Claims Commission (ASCC) denied a claim by Plaintiff related to a contract Plaintiff had entered into with the Arkansas State Highway Commission (ASHC) to complete a highway improvement project. Plaintiff named as defendants the ASCC, the ASHC, and the Arkansas State Highway and Transportation Department (ASHTD). In its complaint, Plaintiff challenged the constitutionality of the method by which the State resolves claims against it, asserting that the procedures violated the Due Process Clause. After a remand by the Supreme Court, the circuit court dismissed Plaintiff’s due process claim and equal protection claim as barred by sovereign immunity. On appeal, Plaintiff argued that the circuit court erred in dismissing its due process claim. The Supreme Court affirmed, holding that Plaintiff failed to demonstrate an unconstitutional act on the part of Defendants that would except its due process claim from the doctrine of sovereign immunity. View "Duit Constr. Co. v. Ark. State Claims Comm'n" on Justia Law

After a jury trial, Appellant was found guilty of four counts of computer exploitation of a child in the first degree in violation of Ark. Code Ann. 5-27-605(a) and of twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child in violation of Ark. Code Ann. 5-27-602(a). On appeal, Appellant argued that the circuit court erred by not reducing each charge to a single count in violation of his right to be free from double jeopardy. The Supreme Court affirmed, holding (1) section 5-27-602 does not impose multiple prosecutions for the same offense in violation of the double jeopardy clause, as the statute authorizes separate convictions for each prohibited photograph and videotape that is possessed; and (2) with respect to his convictions under section 5-27-605, Appellant did not provide any argument explaining how his multiple convictions under the statute result in a double-jeopardy violation. View "Rea v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. Appellant was sentenced to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The trial court denied relief without holding an evidentiary hearing. The Supreme Court affirmed the trial court’s order, holding that, based on a totality of the evidence under the standard set forth in Strickland v. Washington, the circuit court did not clearly err in finding that counsel’s performance was not ineffective. View "Airsman v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without the possibility of parole. For his sole point on appeal, Appellant argued that the circuit court erred in denying his motion to suppress the evidence obtained from a search warrant that resulted in the search of the contents of his cell phone. The Supreme Court affirmed, holding that, based on the facts of this case, there was adequate probable cause to issue the search warrant of Appellant’s cell phone records and that the resulting search was proper. View "Johnson v. State" on Justia Law

After a second trial, Defendant was found guilty of first-degree murder, second-degree battery, and aggravated assault. The court of appeals affirmed the convictions and sentences. Defendant subsequently filed a timely petition for postconviction relief claiming that he had received ineffective assistance of counsel because counsel had failed to request various jury instructions and because counsel was ineffective with respect to his handling of evidentiary issues. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Defendant’s claims of ineffective assistance of counsel and in denying Defendant’s petition without a hearing. View "Sims v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery, theft of property, first-degree battery, and committing a terroristic act in connection with a drug buy. Appellant was sentenced to a total of eighty-seven years in the Arkansas Department of Correction. The court of appeals affirmed. Appellant subsequently filed a petition under Ark. R. Crim. P. 37, alleging ineffective assistance of appellate counsel and that he was improperly convicted of both aggravated robbery and first-degree battery because the first-degree battery charge is a lesser-included offense of aggravated burglary. The State conceded that Appellant was subjected to double jeopardy on the charges of aggravated robbery and first-degree battery. The circuit court denied Appellant’s claim of ineffective assistance of counsel and dismissed the offense of battery in the first degree. The Supreme Court affirmed, holding that appellate counsel provided constitutionally effective assistance. View "Taylor v. State" on Justia Law

After a jury trial, Appellant was found guilty of commercial burglary and criminal mischief in the first degree. Appellant subsequently filed a timely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting that his defense counsel provided ineffective assistance. The circuit court denied the Rule 37.1 petition without holding an evidentiary hearing. Appellant filed a notice of appeal and filed a motion seeking leave to introduce case law. The Supreme Court denied the motion and affirmed the circuit court’s order, holding that the circuit court (1) did not err in dismissing the petition without an evidentiary hearing; and (2) did not err in finding that counsel rendered effective assistance during trial. View "McLaughlin v. State" on Justia Law

After a jury trial, Defendant was found guilty of the rape of his daughter. The court of appeals affirmed. Defendant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was denied effective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s request for relief where Defendant failed to establish that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Henson v. State" on Justia Law