Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Philyaw v. State
After a jury trial in 1981, Petitioner was found guilty of aggravated robbery and sentenced to life imprisonment. Petitioner later filed a petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he may proceed with a petition for writ of error coram nobis, contending that he was deprived of due process and his right to trial by an impartial jury and that his counsel provided ineffective assistance at trial. The Supreme Court denied the petition, holding that the sole claim raised in the petition that could fit within the bounds of a coram-nobis proceeding was the assertion of a Brady violation, but none of evidence set forth by Petitioner in support of his claim rose to the level of a Brady violation. View "Philyaw v. State" on Justia Law
Montgomery v. State
Appellant was convicted of the rape of his six-year-old granddaughter and sentenced to twenty-five years’ imprisonment. Following his unsuccessful appeal, Appellant filed a petition for postconviction relief, alleging that his trial counsel rendered ineffective assistance of counsel. The circuit court denied the petition, but the Supreme Court reversed for a hearing. After a hearing, the circuit court again denied relief. The Supreme Court reversed and remanded for a new trial, holding that Appellant was prejudiced by his trial counsel’s failure to object to testimony given by a social worker, which included the social worker’s impermissible opinion on the child victim’s truthfulness and the credibility of the victim’s claims. View "Montgomery v. State" on Justia Law
Davis v. State
After a jury trial in 1988, Appellant was convicted of capital murder, aggravated robbery, and theft of property. Appellant was sentenced to life imprisonment for the murder conviction. In 1991, Appellant’s convictions for aggravated robbery and theft of property were set aside. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging trial error and ineffective assistance of counsel claims and that the trial court lacked jurisdiction because it entered an amended judgment. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, and therefore, Appellant did not establish a basis for a writ of habeas corpus to issue. View "Davis v. State" on Justia Law
Britt v. State
After a jury trial, Appellant was found guilty of several offenses, including first-degree murder. The case was reversed and remanded. After a retrial, Appellant was again found guilty of first-degree murder and related offenses. Appellant was sentenced to life imprisonment for the first-degree murder conviction. Appellant later filed a pro se petition for writ of habeas corpus, arguing that his life sentence for the murder conviction was illegal because he was a juvenile at the time of the crime. The circuit court dismissed the petition on the grounds that it did not conform to pleading rules. The Supreme Court dismissed Appellant’s appeal and mooted the motions filed in relation to the appeal, holding that, pursuant to Murry v. Hobbs, because Appellant’s life sentence for first-degree murder was not mandatory, this sentence was not illegal under Miller v. Alabama. View "Britt v. State" on Justia Law
Armstrong v. State
After a jury trial, Appellant was found guilty of committing two counts of Class Y felony terroristic acts, four counts of Class B felony terroristic acts, and two counts of battery in the first degree. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging trial error and that his attorney provided ineffective assistance. The trial court denied the petition without a hearing. Appellant appealed, arguing that the trial court erred in denying the petition without a hearing. The Supreme Court affirmed, holding that the trial court did not err in denying relief without holding a hearing. View "Armstrong v. State" on Justia Law
Thornton v. State
After a jury trial, Appellant was found guilty of aggravated residential burglary and use of a firearm in the commission of the offense. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of stating facts that affirmatively supported his claims of prejudice, and accordingly, the trial court did not err in denying relief; and (2) the trial court did not err in denying the petition without an evidentiary hearing. View "Thornton v. State" on Justia Law
Dodge v. State
After a jury trial, Appellant was found guilty of three counts of rape and one count of attempted rape of a minor. Appellant subsequently filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel as well as trial errors based on the admission of a coerced confession, a violation of the prohibition against double jeopardy, and the filing of a defective information. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant’s appeal and declared moot the motions Appellant filed in relation to the appeal, holding (1) trial counsel did not provide constitutionally defective assistance; and (2) Appellant was not entitled to relief on his remaining allegations. View "Dodge v. State" on Justia Law
Robinson v. State
A police officer stopped Defendant for driving with a defective passenger taillight. The officer subsequently arrested Defendant and charged him with driving while intoxicated (DWI), among other offenses. Defendant filed a motion to suppress, arguing that there was no probable cause for the initial traffic stop. The circuit court denied the motion, concluding that there was reasonable cause for the traffic stop. After a jury trial, Defendant was convicted of refusal to submit to a chemical test but was acquitted of the DWI charge. Defendant appealed the denial of his motion to suppress, arguing that because there is no Arkansas statute prohibiting a cracked taillight, the officer did not have probable cause to stop his vehicle. The Supreme Court affirmed, holding (1) the fact that Defendant’s taillight was visibly broken was sufficient probable cause to believe that he may have committed a traffic violation; and (2) therefore, the circuit court correctly concluded that there was probable cause for the officer to stop Defendant. View "Robinson v. State" on Justia Law
Hayes v. State
After a jury trial, Petitioner was convicted of aggravated assault on a family or household member, among other charges. The court of appeals reversed and remanded. On remand, Petitioner sought postconviction relief under Ark. R. Crim. P. 37, arguing that his counsel provided ineffective assistance. The circuit court denied Hayes’s petition. Petitioner appealed from that ruling and then filed a motion to reconsider. The Supreme Court affirmed, holding (1) if any of Petitioner’s allegations were not ruled on by the circuit court, his failure to seek a writ of mandamus barred further action; and (2) the circuit court did not err in finding that Petitioner was not prejudiced by any error on the part of trial counsel. View "Hayes v. State" on Justia Law
Buchanan v. Hobbs
After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. After the conviction was affirmed on appeal and Appellant unsuccessfully filed a petition for writ of habeas corpus, Appellant filed a second petition for habeas relief, alleging that his counsel provided ineffective assistance and that he was being illegally detained. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to provide any factual support for his allegations, and the circuit court did not err in failing to hold a hearing on the petition.
View "Buchanan v. Hobbs" on Justia Law