Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a negotiated plea of guilty in one case to fleeing on foot and possession of methamphetamine and to residential burglary and robbery in another case. Appellant subsequently filed a pro se petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 that encompassed both cases, claiming that his counsel provided ineffective assistance when he entered his plea to the four offenses. The trial court denied postconviction relief. The Supreme Court affirmed the denial of postconviction relief, holding that the claims raised by Appellant in his postconviction motion and argued on appeal were without merit. View "Sherman v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of raping his seven-year-old stepdaughter. After the mandate issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging, among other claims, ineffective assistance of counsel. The trial court dismissed the petition after a hearing. The Supreme Court affirmed, holding (1) the trial court did not clearly err in holding that counsel’s performance was not ineffective; (2) the trial court correctly held that Appellant’s claim of prosecutorial misconduct at trial was not cognizable in a Rule 37.1 proceeding; and (3) Appellant’s claim that he was dissatisfied with his attorney’s representation in the Rule 37.1 proceeding was not grounds to reverse the trial court’s order and remand for a new hearing. View "McNichols v. State" on Justia Law

Appellant, an inmate of the Arkansas Department of Correction, was found guilty of capital murder in the stabbing death of a fellow inmate. Appellant filed a pro se petition for writ of habeas corpus, arguing that the trial court made several errors in its rulings on defense motions during voir dire and during trial and that his counsel provided ineffective assistance. The circuit court dismissed the petition, noting that the action counted as a “strike” pursuant to Ark. Code Ann. 16-68-607. The Supreme Court affirmed, holding (1) Appellant did not show that the court failed to address any issue cognizable in a habeas proceeding; (2) Appellant’s claims of trial error and ineffective assistance of counsel were not within the purview of a habeas proceeding; and (3) inasmuch as Appellant’s petition for writ of habeas corpus failed to state a claim on which relief was merited, the circuit court did not err in declaring that the petition constituted a strike under the statute. View "Tucker v. Hobbs" on Justia Law

Shelley Kane, a resident of Texas, filed for emergency temporary guardianship of T.S., her minor niece, citing the declining health of Lois Swenson, the adoptive mother of T.S. The circuit court appointed Kane as temporary guardian. Thereafter, Swenson challenged the constitutionality of Ark. Code Ann. 28-65-203(f)(1), alleging that it creates a procedural law regarding service. In the meantime, Kane filed for permanent guardianship of T.S. After a final hearing, the circuit court appointed Kane as permanent guardian of T.S. and declared section 28-65-203 constitutional because its provisions are “special proceedings” pursuant to Ark. R. Civ. P. 81. The Supreme Court affirmed, holding that Kane’s appointed guardianship was a special proceeding and excepted from the Rules of Civil Procedure and governed by statute. View "Swenson v. Kane" on Justia Law

Defendant was charged with drug and firearm offenses. Defendant filed a motion to suppress the items discovered during a search of his person and his minivan. The circuit court granted the motion after a hearing. The State appealed, arguing that the circuit court erred as a matter of law (1) by concluding that additional officer testimony was required to support the pat down of Defendant, and (2) when it found that a warrant was required to search a locked safe discovered in Defendant’s minivan. The Supreme Court dismissed the appeal in part and reversed and remanded in part, holding (1) the State’s first point on appeal is not appealable because it involves the circuit court’s consideration of the particular facts of the case and its determination that those facts did not justify the search of Defendant’s person; and (2) the circuit court erred as a matter of law in finding that, absent exigent circumstances, a warrant was required to search the safe in Defendant’s minivan. View "State v. Crane" on Justia Law

After a jury trial, Appellant was convicted of kidnapping. Appellant was sentenced to life imprisonment. Appellant filed a motion for new trial based on juror misconduct, alleging that a certain juror had used her cell phone to post on a social media website during jury deliberation in violation of the circuit court’s instructions not to do so. After a hearing, the circuit court granted Appellant’s motion for new trial, concluding that by posting to Facebook, the juror had disregarded and violated the court’s clear orders and that, as a result, Appellant had not received a fair trial. The Supreme Court dismissed the State’s appeal, holding that the Court did not have jurisdiction over the appeal, as it turned on whether the circuit court’s findings were supported by the unique facts in this case and did not involve the correct and uniform administration of the law. View "State v. Riley" on Justia Law

After a jury trial, Appellant was convicted of delivery of cocaine. The court of appeals affirmed the conviction. Appellant subsequently filed an Ark. R. Crim. P. 37.1 petition, raising several allegations of ineffective assistance of trial counsel, including claims that trial counsel was ineffective for (1) failing to effectively communicate and inform him of a global plea offer, (2) failing to make a proper Batson challenge, (3) failing to pursue a motion to be relieved as counsel, and (4) not being adequately prepared for trial. The circuit court denied postconviction relief. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying relief. View "Mister v. State" on Justia Law

In 2001, Appellant was sentenced on each of three controlled-substance offenses, and in 2007, Appellant was sentenced on each of three controlled-substance offenses. In 2010, the State petitioned to revoke Appellant’s six suspended sentences for the controlled-substances convictions. The circuit court granted the petition, and Appellant was sentenced to a total of fifty-seven years’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, The circuit court denied relief. Appellant appealed, arguing that his trial counsel provided ineffective assistance because counsel never explained to him his maximum sentencing exposure and also misled him about a plea offer. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying relief. View "Mister v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The judgment was affirmed on appeal. Appellant subsequently filed an amended pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was not afforded effective assistance of counsel at trial. After an evidentiary hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the claims raised by Appellant were largely devoid of the factual support required for a finding of ineffective assistance of counsel, and therefore, the trial court did not err in denying relief under Rule 37.1. View "Jones v. State" on Justia Law

Appellant entered a negotiated plea of guilty to one count of first-degree murder and four counts of aggravated robbery. Appellant was sentenced to life imprisonment for each of the charges. The sentencing orders in Appellant’s case referred to Appellant’s parole eligibility after serving one-third of his life sentences. However, parole eligbility was not authorized by the statute in effect at the time the crimes were committed. Appellant filed a petition for writ of habeas corpus, which was denied. On reconsideration, the Supreme Court granted the writ, holding that the sentencing orders entered against Appellant were facially invalid because the circuit court exceeded its authority in sentencing Appellant to life imprisonment with the possibility of parole. Remanded for resentencing. View "Pennington v. Hobbs" on Justia Law