Justia Arkansas Supreme Court Opinion Summaries

Petitioner was found guilty of sexual assault in the second degree and rape and was sentenced to an aggregate term of 720 months' imprisonment. Twenty-one months after the court of appeals issued a mandate affirming the convictions and sentences, Petitioner filed a pro se request for relief that the trial court treated as a petition for postconviction relief. The court dismissed the petition as untimely. Before the Supreme Court was Petitioner's motion for rule on clerk, seeking leave to lodge the record belatedly and proceed with an appeal. The Court denied the motion, holding that because the petition before the trial court was not timely filed, the trial court had no jurisdiction to grant the relief sought, and therefore, the appellate court also lacked jurisdiction. View "Holliday v. State" on Justia Law

Petitioner, proceeding pro se, sought a writ of mandamus and other relief on claims that Circuit Judge David Reynolds had failed to act promptly on pro se pleadings in two criminal cases filed against Petitioner. The Supreme Court requested an amended response on Petitioner's claims concerning the disposition of certain pro se pleadings in one of the cases. In that case, the Supreme Court had originally affirmed the judgment of conviction and reversed and remanded, ordering resentencing. However, the resentencing order was invalid. In response to the Supreme Court's request for an amended response, Judge Reynolds submitted a response to which he attached an amended sentencing order. Because the documentation reflected that a new resentencing order had been entered in the case, the judgment in the case was final, and any underlying motions, including Petitioner's pro se pleadings that were the remaining subject of his mandamus petition at issue, effectively received a disposition. Therefore, Petitioner's request for mandamus relief in regard to those claims was moot. View "Glaze v. Reynolds" on Justia Law

The Arkansas Department of Community Correction (DCC) owned a prison complex in Jefferson County that was part of several tracts of state land annexed to the City of Pine Bluff in 1999. The property was automatically zoned as residential. In 2011, DCC, with the approval of the Board of Correction, decided to use three existing buildings on its property to house persons who had been granted parole. The City objected to DCC's adding transitional housing to its prison complex. The circuit court granted declaratory judgment and injunctive relief in favor of the City, concluding that Ark. Code Ann. 16-93-1603 acted as a waiver of sovereign immunity and that DCC was subject to the zoning laws of the City. The Supreme Court reversed, holding that the circuit court erred in concluding that the General Assembly intended to waive the State's sovereign immunity in section 16-93-1603, and therefore, the circuit court lacked jurisdiction to hear the City's petition pursuant to the doctrine of sovereign immunity. View "Ark. Dep't of Cmty. Corr. v. City of Pine Bluff" on Justia Law

In 1999, Appellant was convicted of multiple felony-drug charges and sentenced to an aggregate life sentence. In 2012, Appellant filed a motion to vacate a void judgment. The circuit court denied the motion, determining that it did not have jurisdiction to consider the motion because the motion was an untimely petition under Ark. R. Crim. P. 37.1. Appellant appealed, asserting that the circuit court did have jurisdiction to consider his claim because he challenged the court's jurisdiction and a challenge to the court's jurisdiction can be raised as a matter of common law without regard to jurisdiction conferred by any statute or rule. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding that Appellant failed to establish that the circuit court had jurisdiction to consider his motion to vacate. View "Watts v. State" on Justia Law

In 1996, Appellant pled guilty to multiple felony offenses. An aggregate sentence of 720 months' imprisonment was imposed. In 2012, Appellant filed a pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. The trial court denied the petition, holding that the petition amounted to an untimely petition for postconviction relief under Ark. R. Crim. P. 37.1. Appellant appealed and filed two motions related to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that whether the petition was one under Rule 37.1 or under the statute, it was not timely filed, and the trial court did not therefore err in denying it. View "Purifoy v. State" on Justia Law

Appellant pled guilty to theft by receiving, being a felon in possession of a firearm, and possession with intent to deliver a controlled substance. Appellant subsequently filed in the circuit court where he was incarcerated a pro se petition for a writ of habeas corpus, contending that the trial court lacked jurisdiction in his case because the felony information charging him with aggravated robbery was defective and that the State did not have jurisdiction over him. The Supreme Court dismissed the appeal and declared the motions Appellant filed in relation to the appeal moot, holding (1) because Appellant failed to properly object to the sufficiency of his indictment prior to trial, he did not establish that the information was defective; and (2) the trial court had jurisdiction over the proceedings. View "Murry v. Hobbs" on Justia Law

The State commenced criminal proceedings against Petitioner by filing an information charging him with second-degree sexual assault. Petitioner filed a pro se motion to dismiss the charge on the basis of a speedy-trial violation, and the circuit court denied the motion. Petitioner then filed a petition before the Supreme Court seeking to halt the proceedings on the basis that the time period in which to bring him to trial had expired. The Supreme Court denied the petition, holding that this was not an appropriate case for interlocutory review of the issue that Petitioner sought to raise, as the motion here was not denied on the merits of the issue presented but rather was denied because the trial court ruled that it would not consider the issues in the pro se motion. View "Kindall v. Circuit Court" on Justia Law

Appellant was a prisoner serving a life sentence on a capital-murder conviction. Appellant filed a petition for writ of habeas corpus in the circuit court of the county where he was incarcerated, claiming that the process of service of the felony information charging him with the crime was constitutionally infirm. The circuit court denied the petition. Appellant lodged an appeal of the circuit court's order and filed a motion seeking an extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Appellant's allegations of constitutional violations involving the process of charging him were not the type of error cognizable in a proceeding for the writ. View "Jones v. Hobbs" on Justia Law

Petitioner filed in the circuit court in the county where he was incarcerated a pro se petition for writ of habeas corpus, alleging, among other claims, that he was denied the effective assistance of counsel. The circuit court dismissed the petition and denied Petitioner's motion for reconsideration. Petitioner appealed. The Supreme Court clerk declined to lodge the record-on-appeal for procedural reasons, and Petitioner filed a motion seeking leave to proceed with the appeal. The Supreme Court denied the motion, holding that Appellant failed to state cognizable claims and therefore did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Hooper v. Hobbs" on Justia Law

Appellant was imprisoned for possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Appellant subsequently filed in the circuit court of the country where he was imprisoned a pro se petition for writ of habeas corpus, claiming (1) his sentence was illegal because it was improperly enhanced using an out-of-state conviction, and (2) counsel was ineffective for failing to challenge the imposition of the enhancement. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in its judgment, as (1) claims of ineffective assistance of counsel are not cognizable in habeas proceedings; and (2) Appellant failed to provide some evidence in support of his illegal sentence claim. View "Darrough v. State" on Justia Law