Justia Arkansas Supreme Court Opinion Summaries

Petitioner, an inmate, filed a pro se petition for writ of habeas corpus. The circuit court granted the petition in part and denied it in part. Petitioner did not timely appeal and subsequently sought leave to proceed with a belated appeal. In support of his motion to proceed with his belated appeal, Petitioner contended that, as a functional illiterate, it was impossible for him to comply with procedural rules. The Supreme Court denied Petitioner’s motion to proceed with the appeal, holding that it was the duty of Petitioner to file a timely notice of appeal, and Petitioner did not establish good cause for his failure to do so. View "Sillivan v. Hobbs" on Justia Law

Appellant pled guilty to several drug-related charges and received five years of supervised probation. Appellant later pled that he had violated the conditions of probation. After a hearing, the circuit court sentenced Appellant to ten years incarceration. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief, asserting that his counsel was ineffective for (1) failing to raise the issue that the revocation hearing had been held outside the sixty-day limitation set by statute, and (2) not asserting that Appellant did not receive adequate notice of the alleged probation violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in its judgment. View "Johnson v. State" on Justia Law

Appellant pleaded guilty to first-degree murder and was sentenced to 480 months’ imprisonment. Appellant later filed a pro se petition for writ of error coram nobis alleging that his guilty plea was coerced and that he was incompetent at the time of entering the plea. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal and mooted his motion for extension of time to file his brief-in-chief, holding (1) Appellant’s allegation that his guilty plea was coerced due to ineffective assistance of counsel was outside the purview of a coram-nobis proceeding; and (2) the issue of Appellant’s competency could have been raised at the time his plea was entered and was not a ground for proceeding with a petition for writ of error coram nobis. View "Harris v. State" on Justia Law

Appellant, an inmate incarcerated under a sentence of life imprisonment without parole, filed a pro se petition for writ of habeas corpus alleging four bases for issuance of the writ, including the allegation that his commitment was invalid on its face because he had been charged with and pleaded guilty to murder in the first degree and had been sentenced for capital-felony murder. The circuit court dismissed Appellant’s petition without a hearing. The Supreme Court affirmed, holding (1) Appellant was charged with a capital felony, which was punishment by life imprisonment without parole; and (2) therefore, Appellant was sentenced correctly, his judgment of conviction was not illegal on its face, and habeas relief was not warranted. View "Gooch v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of possession of methamphetamine with intent to deliver and other drug-related offenses. After Appellant’s convictions were affirmed on appeal, Appellant unsuccessfully filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and, subsequently, a pro se petition for writ of habeas corpus. Appellant later filed a second pro se petition for writ of habeas corpus. The circuit court denied the petition. The Supreme Court affirmed, holding (1) to the extent Appellant argued that he was entitled to habeas relief because the trial court lacked jurisdiction and the authority to sentence him, this claim was barred by the law-of-the-case doctrine; (2) the law-of-the-case doctrine also applied to Appellant’s challenge to his consecutive sentences; and (3) Appellant’s request for jail-time credit was not cognizable in a petition for writ of habeas corpus. View "Bumgarner v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery and misdemeanor theft of property, with a firearm enhancement. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming that he was denied a fair and impartial trial, that his confession was the result of coercion by law enforcement, that his counsel provided ineffective assistance, and that the prosecutor committed misconduct during trial. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in relation to the appeal, holding that the petition was wholly without merit. View "Williams v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts rape and sentenced to four consecutive terms of 480 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging claims of trial error, insufficiency of the felony information, and due process and equal protection violations. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue, and therefore, the trial court did not err in denying the petition. View "Jones v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and sentenced as a habitual offender to life in prison without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his counsel had provided ineffective assistance. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal, denied Appellant’s motion to reinvest jurisdiction in the trial court, and mooted Appellant’s motions for appointment of counsel and to stay appeal, holding that Appellant’s allegations were conclusory or failed to provide a basis for a finding of ineffective assistance of counsel. View "Craigg v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and possessing matter depicting sexually explicit conduct involving a child. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming that he was not afforded effective assistance of counsel. Following a hearing, the trial court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant’s ineffective assistance of counsel claims were either conclusory, not supported by the evidence, not cognizable in a Rule 37.1 proceeding, or without merit. View "Boatwright v. State" on Justia Law

Mike Burcham filed an amended complaint against the Board of Trustees of the University of Arkansas for wrongful discharge. After the circuit court denied the Board’s motion to dismiss based on sovereign immunity, the Board sought extraordinary writs of mandamus, prohibition, and certiorari directed to the Circuit Court of Crawford County to stop the court from proceeding further on the complaint based on lack of venue. The Supreme Court also decided on the day of this opinion, in a separate interlocutory appeal, that the Board was entitled to sovereign immunity. Because of the Court’s conclusion that the Board was indeed entitled to sovereign immunity, the case against the Board was dismissed and the instant petition for extraordinary writs was therefore moot. View "Bd. of Trs. v. Crawford County Cir. Court" on Justia Law