Justia Arkansas Supreme Court Opinion Summaries

Appellant lodged an appeal in the Supreme Court from an order of the circuit court that denied his petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. Appellant filed a motion to be provided a copy of the record and a motion to stay the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding (1) to the extent Appellant's claims were cognizable under Ark. R. Crim. P. 37.1, his request for relief was properly treated as a petition under Rule 37.1 and was subject to the time limitations associated with the rule; and (2) because Appellant's petition was not timely filed under either Rule 37.1 or section 16-90-111, the trial court did not err in concluding that the petition was not timely. View "Hickman v. State" on Justia Law

A jury convicted Appellant of possession of a controlled substance with intent to deliver methamphetamine and sentenced him to life imprisonment without parole. Appellant challenged his conviction on the basis that his right to effective counsel was violated by a conflict of interest and that the trial court abused its discretion in allowing evidence of gang affiliation during the sentencing hearing. The Supreme Court affirmed, holding (1) the Court was precluded from reviewing Appellant's ineffective assistance claim because he did not raise it at the trial court level; and (2) Appellant's claim that the trial court erred in admitting evidence of gang affiliation during the sentencing phase of the trial was also not preserved for appeal. View "Guevara v. State" on Justia Law

Appellant was convicted of four counts of capital murder and one count of kidnapping. On appeal, Appellant contended (1) the State's use of inconsistent prosecutorial theories in his trial and in the separate trial of a co-defendant denied him due process of law; and (2) because the police failed to inform him that he was under no legal obligation to comply with their request to speak with them, Ark. R. Crim. P. 2.3 was violated and any subsequent statements to police should have been suppressed. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's motion to prohibit the prosecution from arguing contradictory theories of the case; and (2) the circuit court's denial of Appellant's motion to suppress his statements was not clearly against the preponderance of the evidence. View "Green v. State" on Justia Law

Appellant appealed an order of the circuit court convicting him of rape for digitally penetrating a seven-year-old child and sentencing him as a habitual offender to life imprisonment. For reversal, Appellant argued that the circuit court erred in denying his motion for directed verdict and that the circuit court abused its discretion in denying his motion in limine to exclude the testimony of witnesses offered pursuant to Ark. R. Evid. 404(b). The Supreme Court affirmed, holding (1) there was substantial evidence to support Appellant's conviction, and therefore, the circuit court properly denied Appellant's motion for directed verdict; and (2) the circuit court did not err in admitting three witnesses' testimony pursuant to Rule 404(b). View "Fields v. State" on Justia Law

Petitioners, individually and on behalf of Coalition to Preserve Arkansas Values (CPAV), brought this original action requesting the Supreme Court to review the legal sufficiency of the popular name and ballot title of the Arkansas Medical Marijuana Act. CPAV requested the Court to declare the popular name and ballot legally insufficient and hold that, if enacted, the Act would conflict with the state and federal constitutions and would violate state and federal law. CPAV further asked the Court to remove the Act from the November 6, 2012 ballot. The Supreme Court denied the petition, holding that the Act's popular name and ballot title were legally sufficient, and therefore, the Act was proper for the inclusion on the ballot at the general election on November 6, 2012. View "Cox v. Martin" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder, first-degree murder, and capital murder. Appellant received an aggregate sentence of life imprisonment without parole. Appellant appealed, contending that the circuit court abused its discretion in excluding fingerprint and trace-DNA evidence of unknown persons found at the crime scene and at the residence of one of the victims. The Supreme Court affirmed the judgment and commitment order after noting that the circuit court correctly found that the evidence Appellant intended to offer was too speculative because it related only to unknown third persons and in so ruling, holding that the circuit court did not abuse its discretion in excluding the proffered evidence pursuant to the Zinger test, which requires that a direct connection with the crime on trial is required. View "Birts v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to a term of life imprisonment without parole. Appellant's sole argument on appeal was that he did not knowingly and intelligently waive his right to counsel because the circuit court failed to adequately warn him about the dangers and disadvantages of self-representation. Specifically, Appellant asserted that the deficiencies the Supreme Court observed in Bledsoe v. State were equally present in this case and required reversal of his conviction. The Supreme Court affirmed the conviction and sentence, holding that, on the record, Appellant made his decision with open eyes, choosing to forego the right to counsel with full awareness of the dangers and pitfalls associated with self-representation. View "Walton v. State" on Justia Law

In 1998, Petitioner was found guilty of rape in a trial to the bench and sentenced as a habitual offender to 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a petition with the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the petition, holding (1) Petitioner's claims of trial error did not form a basis for granting the writ; (2) Petitioner's allegations of newly discovered evidence were not a basis for coram-nobis relief; (3) Petitioner failed to show that the prosecutor committed a violation of Brady v. Maryland; (4) Petitioner's remaining claims were not cognizable in coram-nobis proceedings; and (5) Petitioner did not exercise due diligence in bringing his claims almost fourteen years after he was convicted. View "Thompson v. State" on Justia Law

Appellant William J. Sellers, by and through his attorney, Andrew L. Clark, filed a motion for rule on clerk. Appellant's attorney accepted fault and stated in the motion that the clerk's office rejected Appellant's record due to an untimely notice of appeal. The Supreme Court, therefore, treated Appellant's motion as one for belated appeal. After acknowledging that Appellant's attorney admitted fault, the Supreme Court held that in accordance with McDonald v. State the motion should be granted because Appellant's attorney was responsible for the failure for Appellant to perfect his appeal. The Court also noted that a copy of the opinion would be forwarded to the Committee on Professional Conduct. View "Sellers v. State" on Justia Law

Appellant, by and through his attorney, filed a motion for rule on clerk. Because there was no notice of appeal filed in this case, the Supreme Court treated Appellant's motion as one for belated appeal and remanded for findings on attorney error. On remand, the circuit court found there was no evidence of attorney error. The Supreme Court subsequently denied the motion, holding that because there was no attorney error or other good cause for the failure to file a timely notice of appeal established in the motion, the Court did not need to further consider Appellant's request to proceed with an appeal. View "Reed v. State" on Justia Law