Justia Arkansas Supreme Court Opinion Summaries

The Pulaski County Election Commission and some of its commissioners and the Pulaski County Circuit/County Clerk (collectively, “PCEC”) filed a petition for a declaratory judgment, claiming that certain emergency rules promulgated by the Arkansas State Board of Election Commissioners (“ASBEC”) relating to absentee voters were unconstitutional. The circuit court concluded (1) Act 595 of 2013, which amended the State election code to require that voters provide proof of identity when voting, was unconstitutional; and (2) the emergency rules were also unconstitutional because they were derived from the Act. The Supreme Court affirmed in part and vacated in part, holding that the circuit court (1) did not err in finding that the rules relating to absentee voters promulgated by the ASBEC were unconstitutional; but (2) erred in declaring Act 595 unconstitutional because that issue was not pled or developed before the circuit court. View "Ark. State Bd. of Election Comm'rs v. Pulaski County Election Comm'n" on Justia Law

After a jury trial, Defendant was found guilty of capital murder. The conviction resulted in a sentence of life imprisonment without parole. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief, asserting that he had received ineffective assistance of counsel at trial and on direct appeal. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in ruling that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Watson v. State" on Justia Law

Appellant pleaded guilty to aggravated robbery and commercial burglary and was sentenced to an aggregate term of 240 months’ imprisonment. The court of appeals affirmed the sentence. Appellant subsequently filed a pro se petition for postconviction relief, asserting that his counsel provided ineffective assistance at trial and on direct appeal. The petition was denied. Appellant appealed and filed a motion to have his brief-in-chief duplicated at public expense. The Supreme Court dismissed the appeal and mooted the motion, holding that Appellant’s allegations of ineffective assistance of counsel were not sufficient to establish that he was entitled to postconviction relief. View "Thomas v. State" on Justia Law

After a jury trial in 1977, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. Appellant was sixteen years old at the time of the offense. In 2013, Appellant filed a petition for writ of habeas corpus, asserting that, in accordance with Miller v. Alabama, his life sentence was invalid on its face because the sentencer did not hold a hearing to consider mitigating factors relating to his youth before imposing the maximum sentence of life imprisonment. The petition was denied. The Supreme Court affirmed, holding that Miller was inapplicable to Appellant’s case because Appellant’s 1977 sentence to life imprisonment for first-degree murder was not mandatory and the sentencer was permitted to consider sentencing-related mitigating evidence. View "Smith v. State" on Justia Law

After the Pulaski County Humane Society (PCHS) seized many dogs from Defendant’s premises, Defendant was charged with three felony counts of aggravated cruelty to animals and ten misdemeanor counts of cruelty to animals for keeping her dogs without access to shade in excessively hot temperatures. The jury found Defendant guilty of five misdemeanor counts of cruelty to animals. The circuit court sentenced Defendant to 100 hours of community service and payment of a $500 fine. In a supplemental order, the court ordered Defendant to pay costs to PCHS of $6,425 and divested Defendant of custody of the five dogs that she had been convicted of abusing. Defendant appealed, arguing, inter alia, that the circuit court erred in denying her motion to suppress the evidence related to the seizure of the dogs. The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to suppress evidence but dismissed Defendant’s appeal and the State’s cross-appeal of the circuit court’s supplemental order, holding (1) the circuit court did not clearly err in denying Defendant’s motion to suppress; but (2) the circuit court lacked jurisdiction to decide the State’s petition for divestment and Defendant’s petition for custody of the dogs. View "Nance v. State" on Justia Law

After a jury trial, Appellant was convicted of possession of a controlled substance with intent to deliver and sentenced, as a habitual offender, to life imprisonment. After the Supreme Court affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, alleging that his trial counsel provided ineffective assistance. The circuit court denied relief without a hearing. The Supreme Court reversed, holding that the circuit court erred (1) in relying on email correspondence that was attached to the prosecutor’s response to Appellant’s petition and was not part of the file, record, or petition; and (2) in denying Appellant’s petition in the absence of a hearing because the files and records did not conclusively show that Appellant was entitled to no relief. View "Guevara v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding that the circuit court did not err by (1) failing to stop trial and conduct a competency hearing on its own volition; (2) failing to grant a mistrial after Appellant had an outburst in front of the jury, as the fundamental fairness of the trial was not affected; and (3) requiring Appellant to wear a stun belt, shackles and handcuffs for the remainder of the trial after his outburst in the courtroom, as Appellant’s own conduct brought about the need for restraints, and he was not denied his right to a fair trial. View "Britton v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery, first-degree battery, forgery, and fraudulent use of a credit card. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming that his counsel provided ineffective assistance. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his ineffective assistance of counsel claims and that the trial court did not err in denying Appellant’s request for a copy of the record at public expense. View "Anthony v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and first-degree battery. The court of appeals affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his counsel provided ineffective assistance by failing to interview and call certain witnesses. The circuit court denied postconviction relief. The Supreme Court affirmed, holding that the circuit court did not err in denying relief, where Appellant did not provide any support for his conclusory claims that counsel was ineffective and made no showing that counsel committed any specific error that prejudiced the defense. View "Stiggers v. State" on Justia Law

Appellant was convicted of two counts of rape of his step-granddaughter and sentenced to a term of 480 months. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, claiming that his trial counsel provided ineffective assistance. The Supreme Court affirmed, holding that the circuit court did not clearly err in rejecting without a hearing Appellant’s claim that trial counsel was ineffective for (1) failing to object to defective charging language and jury instruction; and (2) failing to investigate and utilize evidence of a third party’s semen found on the victim’s pants. View "McDaniels v. State" on Justia Law