Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of thirty-seven various sex offenses and sentenced to a total of thirty-seven years incarceration. After Appellant’s convictions were affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that his trial counsel was ineffective for because counsel was simultaneously representing Appellant and Appellant’s wife at the time of Appellant’s trial, and the dual representation created an actual conflict of interest adversely affecting counsel’s performance. The trial court ultimately denied the petition. The Supreme Court reversed, holding (1) an actual conflict of interest existed under the circumstances of this case; and (2) the actual conflict of interest adversely affected counsel’s performance. Remanded for a new trial with conflict-free counsel. View "Rackley v. State" on Justia Law

After a jury trial in 2008, Petitioner was found guilty of aggravated robbery and burglary. Petitioner’s motion for a new trial and petition for postconviction relief were denied. Petitioner subsequently filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court in order that he may proceed with a petition for writ of error coram nobis, claiming (1) his trial counsel was ineffective, (2) newly discovered evidence existed that questioned the credibility of the State’s witnesses, and (3) evidence was withheld by the prosecuting attorney’s office in violation of his constitutional rights, as recognized in Brady v. Maryland. The Supreme Court denied the writ, holding (1) Petitioner’s first two allegations were not a basis for the writ; and (2) Petitioner’s claims of a Brady violation were without merit. View "Burton v. State" on Justia Law

Appellant pleaded guilty to multiple counts of aggravated robbery and theft of property and was sentenced to an aggregate sentence of life imprisonment. Almost twenty years after the judgment had been entered, Appellant filed a pro se petition for writ of error coram nobis. The trial court denied the petition, concluding that the claims were either without merit or not within the purview of a coram-nobis proceeding and that Appellant did not act with due diligence in filing the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the coram-nobis petition. View "Wright v. State" on Justia Law

Appellant pleaded guilty to rape and was sentenced as a habitual offender to 180 months’ imprisonment. Appellant subsequently filed a petition for writ of habeas corpus, making several allegations. The circuit court denied the petition without a hearing, concluding that the allegations were conclusory in nature and failed to state a basis for a writ of habeas corpus to issue. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion to file a belated reply brief, holding that the circuit court did not err when it denied the petition, as Appellant did not establish a basis for a writ of habeas corpus to issue. View "Tolefree v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts of sexual assault of a fourteen-year-old boy. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming dissatisfaction with the trial judge, trial error, and ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted Appellant’s motion for extension of time to file his brief-in-chief, holding (1) the allegations concerning the judge’s conduct did not rise to a showing of fundamental error sufficient to void the judgment; (2) Appellant failed to establish that his attorney was ineffective; and (3) Appellant did not establish that any claim of trial error raised in the petition was sufficient to void the judgment in his case. View "Nelson v. State" on Justia Law

In 1986, Petitioner was found guilty of three felony offenses for which the circuit court imposed an aggregate sentence of life imprisonment. The Supreme Court affirmed. In 2013, Petitioner filed a pro se petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court held that none of Petitioner’s claims was sufficient to void the judgment-and-commitment order and denied the petition. Petitioner subsequently filed a second Rule 37.1 petition, alleging several claims of error that were raised in his original Rule 37.1 petition. The Supreme Court dismissed the petition, holding that Petitioner did not raise a claim sufficient to void the judgment in his case. View "Munnerlyn v. State" on Justia Law

Appellee, who was seventeen years old at the time of the offenses, pled nolo contedere to committing several crimes, including kidnapping. The circuit court sentenced Appellee to life imprisonment for his kidnapping conviction. The U.S. Supreme Court subsequently issued its decision in Graham v. Florida, holding that the Eighth Amendment forbids a sentence of life without parole for a juvenile offender who did not commit homicide. Appellee subsequently filed a writ of habeas corpus alleging that, pursuant to Graham, his life sentence was unconstitutional. After a sentencing hearing, the circuit court sentenced Appellee to a term of forty years’ imprisonment for the kidnapping conviction. The State appealed, arguing that the circuit court erred in not sentencing Appellee to a term of life imprisonment with the possibility of parole. Appellee cross-appealed. The Supreme Court affirmed, holding (1) the circuit court correctly ruled that the maximum sentence available after invalidation of Appellee’s life sentence was forty years; and (2) Graham did not entitle Appellee to additional consideration of his youth or the circumstances of his crime to reduce his sentence even further. View "Hobbs v. Turner" on Justia Law

After a jury trial, Appellant was found guilty of possession of a controlled substance with intent to deliver. Appellant later filed a pro se petition for writ of habeas corpus, contending (1) he was subjected to an illegal search and seizure of evidence and an illegal arrest, and (2) insufficient evidence supported the judgment as revealed in contradictory testimony of witnesses at trial. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared moot the motion filed in relation to the appeal, holding that Appellant failed to raise a claim within the purview of a habeas action and thus failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Green v. State" on Justia Law

After a jury trial, Appellant was found guilty of domestic battery in the first degree. Appellant subsequently filed a pro se petition for postconviction relief, which the trial court denied without a hearing. The Supreme Court affirmed the denial, holding (1) the trial court did not err by not appointing an attorney to represent Appellant on his postconviction petition; (2) Appellant’s challenge to his sentence was not cognizable in a postconviction proceeding; and (3) the trial court did not err in holding that Appellant’s counsel did not provide ineffective assistance under the standard set forth in Strickland v. Washington. View "Ellis v. State" on Justia Law

Defendant entered a conditional guilty plea to trafficking a controlled substance. The court of appeals affirmed. Defendant subsequently filed a petition for review, arguing that the circuit court erred in failing to suppress evidence seized during a traffic stop of the rental cae Defendant was driving because the law enforcement’s placement of a GPS tracking device on the vehicle without a warrant and gathering data about the vehicle’s movements was an unconstitutional search under United States v. Jones. The Supreme Court affirmed without considering Defendant’s argument that planting the GPS device was an unreasonable search under Jones, holding (1) Defendant had no legitimate expectation of privacy in the vehicle and no standing to challenge the search of the rental car; and (2) although Defendant had standing to challenge his own detention, the detention was reasonable. View "Wilson v. State" on Justia Law