Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of three counts of second-degree sexual assault. The conviction was affirmed on appeal. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, raising claims of ineffective assistance of trial counsel and claims of independent constitutional error. The trial court denied postconviction relief. The Supreme Court affirmed, holding (1) Petitioner failed to make required showings under the Strickland analysis that his trial counsel provided ineffective assistance; (2) Appellant failed to demonstrate that appellate counsel was ineffective; and (3) Appellant failed to establish with factual substantiation that his claims of prosecutorial misconduct or due process violations were sufficient to void the judgment in his case, and the trial court’s findings were not clearly erroneous. View "Savage v. State" on Justia Law

There were eight justices of the Supreme Court poised to decide the appeal in Smith v. Wright. However, the Arkansas Constitution provides that the Arkansas Supreme Court “shall be composed of seven Justices.” At issue before the Supreme Court was which justices properly constitute the Supreme Court to decide Smith v. Wright. Specifically, the question was whether Justice Rhonda K. Wood or Special Justice Robert W. McCorkindale should participate in the Court’s disposition of Smith v. Wright. The Supreme Court answered that Justice Wood, having been duly elected by the people and having begun her eight-year term as a Supreme Court justice on January 1, 2015, was the qualified justice invested with the judicial power to participate in Smith v. Wright and that Special Justice McCorkindale’s constitutional authority to participate in the case expired on December 31, 2014. View "Smith v. Wright" on Justia Law

After a jury trial, Appellant was convicted of four counts of fourth-degree sexual assault, possession of a firearm by a felon, two counts of fleeing, and resisting arrest. The court of appeals affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, arguing that the three attorneys who represented him at trial were ineffective. The trial court dismissed and denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the trial court was clearly erroneous in summarily denying postconviction relief. View "Magness v. State" on Justia Law

After a jury trial, Defendant was found guilty of possession of cocaine with intent to deliver, possession of marijuana with intent to deliver, and unauthorized use of property to facilitate a crime. The court of appeals affirmed. Defendant subsequently filed a petition for a new trial pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed the denial of Defendant’s Rule 37.1 petition, holding that the circuit court did not clearly err in refusing to grant relief on the points raised by Defendant. View "Smith v. State" on Justia Law

Appellant pleaded guilty to charges of possession of a controlled substance and possession of drug paraphernalia. Appellant appealed, arguing that the circuit court erred by denying his motion to suppress evidence seized following a traffic stop of his vehicle, claiming that the stop was illegal. The court of appeals affirmed. The Supreme Court reversed the circuit court’s sentencing order and vacated the opinion of the court of appeals, holding that the stop was not based on a reasonable suspicion that Appellant was engaged in criminal activity, and therefore, the circuit court erred by denying Appellant’s motion to suppress. View "Schneider v. State" on Justia Law

Appellant entered a plea of nolo contendere to a single count of sexual assault in the first degree. The circuit court accepted the plea and sentenced Appellant to eight years in prison. Appellant subsequently filed a motion to withdraw his plea pursuant to Ark. R. Crim. P. 26.1, asserting that he had received ineffective assistance of counsel and that he did not voluntarily enter the nolo contendere plea. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the withdrawal of his plea of nolo contendere was necessary to avoid a manifest injustice, and therefore, the circuit court did not abuse its discretion by denying Appellant’s motion to withdraw his plea. View "Martin v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that the evidence was insufficient to support his conviction and that his counsel provided ineffective assistance. The trial court denied the petition. The Supreme Court dismissed the appeal, holding (1) challenges to the sufficiency of the evidence are not cognizable under Rule 37.1; and (2) Appellant’s allegations of ineffective assistance did not meet the standard under Washington v. Strickland for establishing ineffective assistance of counsel. View "Leach v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of rape. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging that he was not afforded the effective assistance of counsel. The trial court denied the petition, concluding that counsel’s performance was not ineffective. Appellant appealed and sought by pro se motion an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Appellant failed to establish that his trial counsel provided constitutionally defective assistance. View "Johnston v. State" on Justia Law

In 1979, Appellant entered a negotiated plea of guilty to attempted capital murder and was sentenced to life imprisonment. Appellant was seventeen when he committed this offense. In 2011, Appellant filed a pro se complaint for declaratory relief alleging that the parole-eligibility statute was unconstitutional as applied to him. Relying on Graham v. Florida, Appellant requested that the circuit court find that his life sentence violated the Eighth Amendment and that he be resentenced to a term of years. The circuit court dismissed the action on summary judgment. Appellant appealed. The Supreme Court reversed, holding that, under Arkansas law, attempted capital murder is not a homicide offense for purposes of Graham. Remanded. View "Bramlett v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted as an accomplice to both capital murder and kidnapping. Appellant was sentenced to life imprisonment without parole on the capital-murder charge. The Supreme Court affirmed, holding that the introduction of the video and transcript of Appellant’s interview with police did not violate her right to confront witnesses against her under the Confrontation Clause of the Sixth Amendment where the police repeated statements made by co-defendants who did not testify at trial because the co-defendants’ statements in this case were not hearsay. View "Swain v. State" on Justia Law