Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Meek v. Arkansas
Appellant Rusty Meek pled guilty to possession of a controlled substance (methamphetamine and hydrocodone) with intent to deliver and possession of drug paraphernalia with intent to use. He was sentenced as a habitual offender and received a 240-month sentence with an additional 120-month suspended imposition of sentence. Appellant appealed pro se to the circuit court. The circuit court denied the petition and motion for production of the trial transcript at public expense. Appellant then appealed that denial, but did not tender the proper notice to the Supreme Court. He then filed a belated pro se motion for appeal. Because the notice of appeal was timely, the Supreme Court treated the motion as a motion for rule on clerk to perfect the appeal rather than as a motion for a belated appeal. Finding that Appellant could not prevail on his original motion, the Supreme Court affirmed the circuit court's decision to dismiss Appellant's petition. View "Meek v. Arkansas" on Justia Law
Watts v. Arkansas
The circuit court found no merit to defendant Frank Watts, II's pro se petition for the writ of habeas corpus and dismissed it. Defendant appealed that decision. Finding no clear error to the circuit court's decision, the Supreme Court affirmed. View "Watts v. Arkansas" on Justia Law
Stevenson v. State
After a bench trial, Defendant was convicted of rape. Defendant subsequently filed a petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel. The circuit court denied the petition. Defendant appealed and filed motions for an extension of time to file his brief-in-chief and for a copy of the record on appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that Defendant failed to provide facts affirmatively supporting the claims that his counsel's conduct prejudiced him under the standards set out in Strickland v. Washington. View "Stevenson v. State" on Justia Law
Hodges v. State
In 1994, Defendant pled guilty to attempted rape and to violation of a minor. Defendant committed the offenses in 1992 or 1993. Defendant was sentenced to concurrent terms of twenty years' imprisonment for the attempted rape charge. In 2010, Defendant filed a pro se petition to correct an illegal sentence, arguing that his twenty-year sentence amounted to an ex-post-facto violation because the court applied the transfer-eligibility statute, which became effective in 1994, to his sentence. Specifically, Defendant alleged that the parole-eligibility statute in effect at the time of the commission of the crime should be applied to his sentence. The circuit court denied Defendant's petition. The Supreme Court affirmed, holding that because Appellant's petition was untimely, the circuit court did not err in denying the petition. View "Hodges v. State" on Justia Law
Bond v. State
After a jury trial, Defendant was convicted of multiple drug-related offenses. The court of appeals affirmed. Defendant subsequently filed a petition for postconviction relief, alleging that his trial counsel was ineffective for failing to impeach one of the state's witnesses, failing to object to comments made by the State in closing arguments, and failing to challenge the jury-selection process, among other reasons. The circuit court denied Appellant's petition without a hearing. The Supreme Court affirmed the denial of postconviction relief on all points, holding that the circuit court did not commit prejudicial error in denying postconviction relief. View "Bond v. State" on Justia Law
Rodgers v. State
After a jury trial, Petitioner was convicted of rape and sentenced as a habitual offender to life imprisonment. Petitioner subsequently filed a pro se petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis. After the petition was denied, Petitioner filed another pro se petition seeking leave to have jurisdiction reinvested in the trial court to consider a coram-nobis petition. The Supreme Court dismissed the petition, holding that Petitioner's successive application for coram-nobis relief was an abuse of the writ in that Petitioner alleged no facts sufficient to distinguish his claim in the instant petition from the claim in the first. View "Rodgers v. State" on Justia Law
Kiesling-Daugherty v. State
Defendant was fined in the district court for driving sixteen miles over the speed limit. On appeal, Defendant was convicted of speeding in excess of fifteen miles per hour over the speed limit. The court of appeals reversed and dismissed Defendant's conviction. Defendant subsequently filed a motion for award of costs on appeal under Ark. R. Sup. Ct. 6-7. The Supreme Court accepted certification from the court of appeals to determine whether the State may be liable for costs under Rule 6-7. The Supreme Court denied the motion for costs on appeal, holding that Defendant's claim against the State was barred by the doctrine of sovereign immunity. View "Kiesling-Daugherty v. State" on Justia Law
James v. State
After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was not afforded effective assistance of counsel at trial. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant's allegation that his trial counsel was ineffective for failing to call a witness during the penalty phase of his trial was conclusory and thus without merit; and (2) the trial court did not err in finding Defendant's claim that his attorney should have secured a change of venue was conclusory in nature and not supported by facts. View "James v. State" on Justia Law
Hill v. State
After a jury trial, Defendant was found guilty of murder in the first degree and sentenced to life imprisonment. Defendant subsequently filed a petition for postconviction relief, which was denied. Thereafter, Defendant filed a successive petition to correct an illegal sentence, arguing that his sentence was illegal because the State was allowed to amend the information to charge him with first-degree murder by premeditation and deliberation. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant's petition, as the sentenced imposed was within the sentencing range for the offense of first-degree murder. View "Hill v. State" on Justia Law
Walton v. State
Appellant pleaded guilty to several drug offenses in 2006. The circuit court sentenced Defendant to thirty-six months' imprisonment along with eighty-four months' suspended imposition in sentence. In 2010, the State filed a petition to revoke Appellant's suspended sentence. Appellant pleaded no contest. The circuit court then revoked Appellant's suspended sentence and sentenced him to 168 months' imprisonment. Appellant subsequently filed a pro se petition to correct an illegal sentence, arguing that the circuit court's revocation order was beyond the statutory maximum to which he was originally exposed. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's sentence of 168 months' imprisonment upon revocation was within the statutory limits to which he was originally exposed. View "Walton v. State" on Justia Law