Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Appellant was convicted of second-degree murder, endangering the welfare of a minor, and fleeing. Appellant received a total sentence of 1188 months' imprisonment. Appellant filed a notice of direct appeal, which remained pending in the court of appeals. Two days later, Appellant filed a petition for postconviction relief. The circuit court dismissed the petition, concluding that it lacked jurisdiction to consider the petition while Appellant's direct appeal of his conviction was pending. The Supreme Court dismissed Appellant's appeal of the denial of his petition for postconviction relief and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant's petition for postconviction relief was untimely, and therefore, the trial court and appellate court lacked jurisdiction to grant relief. View "Slocum v. State" on Justia Law

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Appellant entered a plea of guilty in Howard County to breaking or entering and theft of property. While incarcerated, Appellant filed a pro se petition for writ of habeas corpus contending that Howard County did not have jurisdiction in this case because the information and warrants leading to Appellant's arrest were not signed by the circuit judge and stamped with the judge's seal and that the arrest was illegal. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant did not establish that a writ of habeas corpus was warranted in this case, as Appellant failed to assert allegations that were cognizable in a habeas proceeding. View "Roberson v. State" on Justia Law

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In 2010, voters in the Fayetteville School District approved a 2.75 new-debt-service mills that would be a continuing debt service tax until the retirement of proposed bonds to be issued for the purpose of erecting and maintaining new and existing school facilities. The surplus revenues produced by debt service millage would be used for other school purposes. In 2011, certificates issued by the Washington County tax collector resulted in 1.45 mills of that 2.75-mill ad valorem increase being applied to the retirement of redevelopment-district bonds issued in 2005. The School District sought declaratory judgment and injunctive relief. The circuit court found that the assessor's certification was incorrect and that the tax collector improperly applied the 1.45 mills. The Supreme Court affirmed, holding (1) the present cause of action was not barred by res judicata; (2) Ark. Code Ann. 14-168-301(18)(B)(i) did not impair the bond-purchase contract and financing of the redevelopment bonds; and (3) the 2.75 expressly pledged the new millage to a bond in accordance with section 14-168-301(18)(B)(i). View "City of Fayetteville v. Fayetteville Sch. Dist. No. 1" on Justia Law

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After a jury trial, Appellants Ricky Bruner and Melissa Workman were convicted of first-degree battery against their son. Bruner was sentenced to forty years in prison, and Workman received a sentence of life imprisonment. The Supreme Court affirmed Appellants' convictions and sentences, holding that the circuit court (1) did not abuse its discretion in excluding evidence of Appellants' mental condition; (2) did not err by failing to give an instruction on the lesser-included offense of third-degree battery; and (3) did not err in refusing to give a proffered jury instruction defining the phrase "manifesting extreme indifference to the value of human life." View "Bruner v. State" on Justia Law

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Appellant entered a conditional plea of guilty to one count of commercial burglary, reserving his right to appeal the denial of his motion to dismiss for a speedy-trial violation. On appeal, Appellant argued that the circuit court erred by denying his motion to dismiss because the State allegedly intentionally delayed the start of his twelve-month speedy-trial period by refusing to serve the arrest warrants issued for him when they knew he was incarcerated. The Supreme Court affirmed, holding that Appellant's argument had no merit, as the speedy-trial period begins to run on the date of arrest or service of summons and not when an arrest warrant has been issued, and therefore, the speedy-trial period had not yet expired at the time Appellant filed his motion to dismiss. Therefore, the circuit court properly denied the motion to dismiss. View "Robinson v. State" on Justia Law

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Petitioner was convicted of capital murder and sentenced to the death penalty. After a mandatory review of Petitioner's conviction and sentence, the Supreme Court issued a mandate affirming the trial court's judgment. Petitioner subsequently petitioned the Supreme Court to recall its mandate and also filed a petition to reinvest the circuit court with jurisdiction to consider a petition for writ of error coram nobis. The Supreme Court denied both petitions, holding (1) Petitioner failed to demonstrate extraordinary circumstances resulting in a defect in the appellate process that warranted recall of the Court's mandatory-review mandate; (2) Petitioner failed to demonstrate that a recall of a the mandatory-review mandate was necessary based on Petitioner's allegation that there was an alleged breakdown in the postconviction process; and (3) Petitioner failed to proceed with diligence in pursuing coram nobis relief. View "Roberts v. State" on Justia Law

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Petitioner was convicted of capital murder and sentenced to the death penalty for the murder of a twelve-year-old. Following his conviction, Petitioner filed a waiver of his right to appeal and postconviction review. Petitioner subsequently sought to rescind that waiver and asserted several bases on which the Supreme Court should reopen his postconviction proceedings and reinvest jurisdiction in the circuit court. The Supreme Court granted Petitioner's motion, holding that the Court previously failed to ensure that Petitioner was indeed competent to waive his rights to postconviction relief, and such extraordinary circumstances required the Court to reopen the proceedings. View "Roberts v. State" on Justia Law

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After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole. Appellant subsequently filed a petition for writ of habeas corpus, arguing that his life sentence was illegal because he was a minor when the crime was committed. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared Appellant's motions for appointment of counsel and extension of brief time moot, holding that Appellant failed to demonstrate that his sentence was illegal under Miller v. Alabama, and therefore, it was clear that Appellant could not prevail if his appeal were allowed to proceed. View "Murry v. Hobbs" on Justia Law

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Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Forty-four months after the judgment of conviction had been entered against him, Appellant filed a petition under Act 1780 of 2001 to vacate or set aside the judgment. The circuit court denied the petition. Appellant appealed and requested an extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion for extension of time moot, holding that the decision to deny the requested relief was not clearly erroneous, as (1) Appellant failed to rebut the presumption against timeliness on his request for DNA testing; and (2) none of the other claims that Appellant raised were grounds for relief under Act 1780. View "Foster v. State" on Justia Law

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After a jury trial, Defendant was convicted of capital felony murder and aggravated robbery, with a firearm enhancement on each count. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. The Supreme Court affirmed, holding (1) the evidence supported a conclusion that Defendants death occurred during the commission of an aggravated robbery under circumstances manifesting extreme indifference to the value of human life, and thus Defendant's convictions were supported by sufficient evidence; and (2) Defendant failed to preserve for appeal his final two arguments, including his claim that the circuit court erred in prohibiting defense counsel from informing the jury that Defendant would be automatically sentenced to life without parole if convicted of capital felony murder. View "Bradley v. State" on Justia Law