Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment. More than two decades later, Appellant filed a pro se petition for writ of habeas corpus in the circuit court, alleging error in his trial. The circuit court dismissed the petition. On appeal, Appellant contended that an automatic sentence of life without parole is illegal on its face and a violation of the state and federal constitutional prohibition of ex post facto laws. The Supreme Court affirmed, holding that because Appellant's claims did not challenge the facial validity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Jones v. Hobbs" on Justia Law

In 1984, Appellant was charged in drew County with rape. The trial was held in Ashley County. A jury found Appellant guilty, and the judgment-and-commitment order was entered in Drew County. Appellant challenged the sentencing court's jurisdiction on appeal. The Supreme Court affirmed with the modification that the judgment-and-commitment order be filed in Ashley County. In 1984, Appellant also pled guilty to three additional felony offenses, and in 2007, Appellant pled guilty to eight more felony offenses. In 2011, Appellant filed a petition for writ of habeas corpus, which the circuit court dismissed. The Supreme Court affirmed, holding (1) Appellant's contention that the change of venue from Drew to Ashley county rendered the judgment in that case void was barred by res judicata; and (2) the remainder of Appellant's claims were not grounds for habeas relief. View "Douglas v. Hobbs" on Justia Law

Appellant pled guilty to two counts of rape in the Garland County Circuit Court. Appellant subsequently filed a pro se petition for writ of habeas corpus in the trial court in Garland County. At the time the petition was filed, Appellant was incarcerated at the Arkansas Department of Correction located in Hot Spring County. The trial court denied the petition. Appellant appealed and filed a motion to file a belated brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the Garland County Circuit Court did not have personal jurisdiction to issue a writ of habeas corpus where Appellant was not in custody within the court's jurisdiction. View "Cooper v. Hobbs" on Justia Law

After a jury trial, Defendant was convicted of five counts of committing a terroristic act and one count of possession of a firearm by a felon. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging, among other things, that his counsel was ineffective. The trial court denied the petition. The Supreme Court affirmed, holding that counsel did not provide ineffective assistance for (1) deciding not to challenge the information; (2) not challenging the jury instructions or verdict forms that tracked the elements of the charged crimes; and (3) failing to make a sufficient motion for a directed verdict to preserve a sufficiency-of-evidence argument for appeal. View "Anderson v. State" on Justia Law

Petitioner Southern Farm Bureau Casualty Insurance Company petitioned for a writ of prohibition with the Supreme Court, arguing the circuit court did not have jurisdiction after ninety days to set aside its previous order in this case. This matter stemmed from a motorcycle accident in which Stuart Parsons was injured with an uninsured driver. Parsons had uninsured-motorist coverage with Farm Bureau. He made a claim against that coverage, and signed a release allowing farm bureau to obtain his medical bills, and received a personal-injury protection payment. Parsons' medical bills exceeded the policy limit. Farm Bureau them filed a complaint for interpleader, requesting the circuit court disburse its uninsured-motorist limits. At that time, no other party had filed a lien nor claimed any interest in the policy proceeds. Acting pro se, Parsons answered and requested his policy be paid to him. The circuit court ordered Farm Bureau to deposit the funds into the court's registry and to disburse the money accordingly. Then Parsons filed a counterclaim seeking a statutory penalty, interst and attorney's dees, and to dismiss Farm Bureau's interpleader. After a hearing, the circuit court vacated an earlier order thereby allowing Parsons to proceed with his counterclaims against Farm Bureau. Farm Bureau then filed for a writ of prohibition, arguing the circuit court had no jurisdiction to set aside the order after ninety days from entry of the order. The Supreme Court considered Farm Bureau's petition for a writ of prohibition as a request for a writ of certiorari, and found that Farm Bureau had another adequate remedy. As such, the Court denied Farm Bureau's petition for certiorari, and dismissed the petition for the writ of prohibition as moot. View "S. Farm Bureau Cas. Ins. Co. v. Parsons" on Justia Law

A circuit court affirmed an administrative decision from the Arkansas Department of Human Serices Office of Appeals and Hearings which placed Appellant Jose Marrufo on the Arkansas Child Maltreatment Central Registry. On appeal, Appellant raised two issues: (1) because the Department failed to timely conduct an administrative hearing within the statutory time frame (180 days), the proceedings against him should have been dismissed; and (2) the administrative law judge erred in failing to consider his affirmative defense to placement on the Registry. Finding no error, the Supreme Court affirmed. View "Marrufo v. Ark. Dep't of Human Servs." on Justia Law

Appellant Earl Maxwell entered a negotiated guilty plea to two counts of delivery of methamphetamine, two counts of possession with intent to deliver, and one count of possessing drug paraphernalia. He was given a 480-month sentence. Appellant filed a pro se petition for the writ of habeas corpus, which was denied. Finding no error, the Supreme Court affirmed. View "Maxwell v. Hobbs" on Justia Law

Appellant Dellemond Cunningham was found guilty of being an accomplice to aggravated robbery, theft of property, and of being a felon in possession of a firearm, in addition to intimidating a witness. He received a 444-month sentence. He appealed the witness-intimidation conviction in a pro se application for post-conviction relief, which was denied by the circuit court. Finding no error, the Supreme Court affirmed denial of relief. View "Cuningham v. Arkansas" on Justia Law

Appellant Lloyal Bryant was convicted of rape and second-degree sexual assault. He received an aggregate life sentence plus forty years'. He filed pro se a petition for post-conviction relief, which was ultimately denied. Finding no error in the circuit court's denial of relief, the Supreme Court affirmed the conviction and sentence. View "Bryant v. Arkansas" on Justia Law

Appellant Ronald McClure entered a negotiated guilty plea to first-degree murder. He received a 540-month sentence. Appellant pro se filed a petition for the writ of error coram nobis, alleging that because of his trial counsel's failure to investigate and properly advise him of the ramifications of the plea bargain, he was coerced into entering that plea. The circuit court denied appellant's request, finding appellant did not act diligently in filing his petition nine years after the judgment was entered, and that he failed to prove the existence of some fact not known at trial that would have prevented entry of that judgment. Appellant appealed the circuit court's decision. Finding no error or abuse of discretion in the circuit court's decision, the Supreme Court affirmed. View "McClure v. Arkansas" on Justia Law