Justia Arkansas Supreme Court Opinion Summaries

A man was charged with capital murder, rape, kidnapping, and residential burglary after confessing to abducting, sexually assaulting, and killing a six-year-old girl who was his neighbor. The prosecution presented evidence including his detailed confession, DNA linking him to the crime, and medical testimony supporting the cause of death and sexual assault. During the penalty phase, the defense introduced extensive mitigating evidence about his traumatic and abusive childhood, including substance abuse by his mother, physical and sexual abuse, learning disabilities, and his low intellectual functioning.Following a jury trial in the Benton County Circuit Court, the defendant was convicted on all charges and received the death penalty for capital murder, along with life sentences and additional imprisonment for the other offenses. The defense’s mitigation efforts included testimony by social workers, family members, and mental health experts, but the jury found that aggravating circumstances outweighed the mitigating evidence. The Arkansas Supreme Court had previously affirmed his convictions and sentences on direct appeal.The Supreme Court of Arkansas reviewed the denial of his postconviction petition, which alleged ineffective assistance of counsel on several grounds, including failure to adequately investigate and present evidence of childhood sexual abuse and fetal alcohol spectrum disorder (FASD), omission of a mitigating instruction regarding his lack of criminal history, and wrongful concession of guilt without his consent. The court held that trial counsel was not deficient in its investigation or presentation of mitigating evidence, found no prejudice from the omission of certain mitigators, determined that the concession of guilt was a reasonable strategic decision under the circumstances, and rejected arguments regarding verdict forms and cumulative error. The Supreme Court of Arkansas affirmed the lower court’s denial of postconviction relief. View "HOLLY v. STATE OF ARKANSAS" on Justia Law

After a long-term romantic relationship began to deteriorate between Elijah Singleton and Ja’Keya Hampton, Singleton stole Hampton’s cellphone and refused to return it. The day before Hampton’s death, the two communicated via Facebook Messenger, arranging to meet so Singleton could return the phone. Hours later, Hampton was found dead in her car from a gunshot wound. Surveillance footage captured the shooting, with audio indicating Hampton called out to Singleton moments before being shot. After the incident, Singleton attempted to elude law enforcement and destroy evidence, but was arrested following a standoff. He was charged with capital murder and a firearm enhancement.During jury selection in the Crittenden County Circuit Court, a prospective juror who worked at the county jail expressed concerns about a conflict of interest in open court, prompting Singleton to move for a mistrial, which was denied. The State exercised peremptory strikes against four Black prospective jurors. Singleton raised a Batson challenge, arguing the strikes were racially motivated. The State provided race-neutral reasons, such as relationships with the victim’s family, perceived reluctance to serve, and inattentiveness. The circuit court credited the State’s reasons, found them race-neutral, and denied the Batson challenge. Singleton was convicted of first-degree murder and employing a firearm, and sentenced as a habitual offender.On appeal, the Supreme Court of Arkansas reviewed Singleton’s claims that the circuit court erred in denying his mistrial motion and his Batson challenge. The court held there was no abuse of discretion in denying the mistrial because the prospective juror’s statement did not prejudice the jury. It further held that the circuit court’s findings regarding the Batson challenge were not clearly against the preponderance of the evidence. The Supreme Court of Arkansas affirmed the convictions. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

Following the discovery of Van Stevens’s brutal murder in Searcy, Arkansas, police identified Christopher Coy Gamble as a suspect based on his proximity to the crime and evidence tying him to the victim’s residence. Gamble, who was on parole at the time, was observed near the crime scene and was linked to incriminating items found at a neighbor’s property, including belongings previously returned to him by police. Surveillance footage, eyewitness accounts, and a custodial statement in which Gamble admitted being in the victim’s home further implicated him, although Gamble denied committing the murder.The White County Circuit Court conducted a jury trial, during which Gamble moved to suppress his custodial statement, arguing it resulted from a pretextual arrest, and sought to strike the venire after a potential juror expressed an opinion of his guilt. The circuit court denied both motions, finding no grounds for suppression or for striking the jury panel, and a jury subsequently convicted Gamble of capital murder and aggravated residential burglary, resulting in life and sixty-year sentences, respectively.The Supreme Court of Arkansas reviewed the case. On appeal, Gamble challenged the denial of his suppression motion, relying on State v. Sullivan, which barred pretextual arrests under the Arkansas Constitution. The Supreme Court of Arkansas overruled Sullivan, holding that Arkansas’s constitutional standard mirrors the federal “reasonableness” test: an arrest is lawful if supported by probable cause, regardless of the officer’s subjective motivation. The court concluded Gamble’s arrest was proper because he possessed drug paraphernalia in the officer’s presence. The court also found no abuse of discretion in denying Gamble’s motion to strike the venire, as the circuit court’s admonition sufficiently cured any potential prejudice. The Supreme Court of Arkansas affirmed Gamble’s convictions. View "GAMBLE v. STATE OF ARKANSAS" on Justia Law

In July 2011, Roschell Lamb reported to police that she had been raped by a stranger who dragged her into a shed and assaulted her. The police investigation initially yielded no suspects, and the case went dormant until 2018, when Roy Nichols was identified as a suspect through DNA evidence. After locating Lamb in 2023, the State charged Nichols with rape. Nichols claims the encounter was consensual and seeks to introduce evidence that he and Lamb had a prior sexual relationship, specifically alleging they had sex weeks before the incident.The Craighead County Circuit Court held an in camera hearing regarding Nichols’s motion to introduce evidence of the alleged prior sexual encounter. Nichols testified about the supposed prior relationship, and his mother and sister claimed Lamb had visited their home looking for Nichols around the time of the alleged rape. The circuit court found Nichols’s testimony about prior consensual sexual conduct probative of consent and allowed him to testify about it and cross-examine Lamb on the topic, but excluded testimony from Nichols’s mother and sister. The State appealed this evidentiary ruling.The Supreme Court of Arkansas reviewed the circuit court’s decision for abuse of discretion. It concluded the circuit court erred because Nichols’s claim was uncorroborated, only marginally probative, and highly prejudicial. The Court held that Arkansas’s rape-shield statute generally prohibits introduction of evidence of prior sexual conduct unless it is acutely probative and corroborated. The Court also found that Nichols’s Confrontation Clause argument was unavailing, as he could challenge Lamb’s credibility through other means. The Supreme Court of Arkansas reversed the circuit court’s ruling and remanded the case for proceedings consistent with its opinion. View "STATE OF ARKANSAS v. NICHOLS" on Justia Law

In January 2019, a shooting occurred at a gas station in Helena-West Helena, Arkansas, resulting in the death of Casey Grant and serious injury to Raymond Clark. Security footage captured the incident, and multiple witnesses, including law enforcement officers familiar with the accused, Vann Bragg, identified him as one of the shooters. Testimony from Bragg’s co-defendant, Robinson, corroborated Bragg’s involvement, as did statements from the surviving victim. Bragg was convicted by a Phillips County jury of first-degree murder and first-degree battery in June 2021.After his conviction, Bragg’s direct appeal to the Supreme Court of Arkansas was unsuccessful, and the court also affirmed the denial of his petition for a writ of error coram nobis. Bragg then filed a timely Rule 37 petition in the Phillips County Circuit Court, alleging ineffective assistance of counsel on several grounds, including failures to challenge witness identifications, introduce impeachment evidence, present an exculpatory affidavit, call his brother as a witness, and investigate or present mitigation evidence at sentencing. The circuit court held a hearing, considered testimony from multiple witnesses, and subsequently denied Bragg’s petition in a detailed order, finding that none of his claims established deficient performance or prejudice as required under Strickland v. Washington.The Supreme Court of Arkansas reviewed the circuit court’s denial of the Rule 37 petition for clear error. The court held that Bragg failed to demonstrate either deficient performance by his trial counsel or resulting prejudice under the Strickland standard on any of his claims. The court also found no cumulative error, as no individual errors were established. Consequently, the Supreme Court of Arkansas affirmed the circuit court’s denial of Bragg’s Rule 37 petition. View "BRAGG v. STATE OF ARKANSAS" on Justia Law

In this case, the appellant was convicted by a Drew County jury in 1996 for capital murder during a robbery, based largely on eyewitness identifications, physical evidence linking him to the crime, and his own conflicting statements about his involvement. At trial, two witnesses identified him as fleeing the scene with a weapon, and forensic testimony indicated that the victim’s blood type matched stains found on the appellant’s shirt. The appellant testified that he was outside during the shooting, but earlier statements placed him inside as a lookout. His conviction and life sentence were affirmed on direct appeal. The appellant subsequently filed multiple petitions for postconviction relief. In 2012, he sought DNA testing under Act 1780 of 2001, claiming actual innocence and arguing that DNA analysis of blood evidence would exonerate him. The Drew County Circuit Court denied relief, and the Supreme Court of Arkansas affirmed, finding he failed to rebut timeliness presumptions. In 2020, he filed another petition, seeking new DNA testing using methods not previously available, such as M-VAC technology, on various items from the crime scene. The circuit court again denied the petition, ruling it was an impermissible successive filing and that the issues had already been decided. The Supreme Court of Arkansas reviewed this appeal and affirmed the lower court’s decision. It held the petition was both successive and untimely under Arkansas law. The Court found that the appellant’s request for newer DNA testing did not distinguish his claim from earlier petitions in a way sufficient to overcome legal bars or the presumption against timeliness. Additionally, the Court found the proposed testing would not significantly advance a claim of actual innocence, given the weight of the evidence at trial. The Court also concluded that no evidentiary hearing was required under these circumstances. View "HUSSEY v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury in Johnson County, Arkansas, of capital murder, aggravated robbery, and theft of property. The evidence at trial included admissions by the appellant that he intended to rob the victim, that he stabbed her in the throat (which was the fatal wound), and that he stole her car and used her credit cards after her death. DNA evidence connected the appellant to the victim, and multiple witnesses, including the appellant’s sister and a friend, testified to his admissions and actions following the crime. After his conviction was affirmed on direct appeal by the Supreme Court of Arkansas, the appellant filed a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37.1 in the Johnson County Circuit Court. He claimed ineffective assistance of counsel for failure to investigate a laptop allegedly containing exculpatory evidence and unidentified DNA found on a knife, asserted a violation under Brady v. Maryland for alleged suppression of the laptop, and argued that the prosecutor knowingly presented false testimony. The circuit court denied and dismissed the petition, finding that the claims were not supported by the record or were not cognizable in a Rule 37.1 proceeding. The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s denial and dismissal of the appellant’s petition. The court held that the appellant failed to present evidence supporting his claims, and his ineffective assistance of counsel argument lacked factual substantiation. The court also found the Brady claim and the argument regarding false testimony were either unsupported by evidence or not appropriate for postconviction relief under Rule 37.1. The Supreme Court of Arkansas concluded that the circuit court did not clearly err and affirmed its decision. View "OLIGER v. STATE OF ARKANSAS" on Justia Law

The case concerns a man convicted of first-degree murder and a firearm enhancement following the fatal shooting of his business partner outside her home. The two had operated a food-truck business together, and on the day in question, the defendant was seen at the victim’s home with her truck. Several eyewitnesses, including members of the victim’s family and neighbors, testified about the events surrounding the shooting, identifying the defendant as present at the scene and as the person leaving in the victim’s truck after the shooting. After the crime, the defendant abandoned his business and job and evaded police for months, fleeing from law enforcement in both Texas and West Virginia before being apprehended. The Pulaski County Circuit Court, Seventh Division, presided over the defendant’s postconviction petition, which was filed under Arkansas Rule of Criminal Procedure 37.1. The defendant, initially pro se and later represented by counsel, alleged ineffective assistance of trial counsel on five grounds. At a hearing, the court considered evidence and testimony, including from trial counsel and an investigator. The court found that the defendant failed to show trial counsel’s performance was deficient under the standard established by Strickland v. Washington, and that no prejudice resulted from the alleged deficiencies. The court denied the petition. The Supreme Court of Arkansas reviewed the case. Applying the “clearly erroneous” standard, the court examined the trial court’s findings and the three ineffective-assistance claims raised on appeal: insufficient cross-examination of witnesses, failure to investigate the crime scene, and failure to obtain dashcam footage of the police chase. The Supreme Court concluded that the record showed effective cross-examination, that information about the scene was provided to the jury, and that counsel’s actions regarding the dashcam did not constitute ineffectiveness. The Supreme Court affirmed the lower court’s denial of postconviction relief. View "DORSEY v. STATE OF ARKANSAS" on Justia Law

An emergency-room physician and his girlfriend were driving on a highway when the girlfriend died under suspicious circumstances. The physician was the only person present with her at the time. He called 911 and told responders that she was having a seizure. Passersby and responders noted that the physician acted erratically and did not attempt to help. Medical personnel observed significant injuries to the girlfriend’s neck, and an autopsy concluded that she died from strangulation, though the defense’s expert disputed the cause. Text messages presented at trial revealed prior threats from the physician toward the girlfriend.The case was tried in the Chicot County Circuit Court before a jury, which heard conflicting testimony from expert witnesses about the cause of death. The defense argued that the cause was undetermined and that death could have resulted from medical intervention or natural causes. The State’s expert concluded the death was a homicide by strangulation. The jury found the physician guilty of second-degree murder and he was sentenced to thirty years’ imprisonment and fined. After trial, the defense moved for a new trial, alleging juror misconduct based on an affidavit from a juror. The trial court held a hearing, heard testimony from the relevant jurors, and denied the motion for a new trial, finding no credible evidence of misconduct.The Supreme Court of Arkansas reviewed the appeal and held that there was substantial evidence to support the conviction for second-degree murder, that the circuit court did not abuse its discretion in instructing the jury on second-degree murder as a lesser-included offense, and that there was no reversible error in denying the motion for a new trial based on alleged juror misconduct. The Supreme Court of Arkansas affirmed the conviction and vacated the Court of Appeals' opinion. View "TAIT v. STATE OF ARKANSAS" on Justia Law

A man was convicted by a jury of raping his then-girlfriend’s 14-year-old daughter, following evidence that included sexually explicit electronic messages he sent to the minor, testimony from the victim about the assault, and testimony from another of his daughters describing similar sexual abuse. The victim disclosed the assault to her mother immediately after it occurred, but her mother did not initially believe her or contact authorities. Several years later, the mother received messages from the defendant describing further sexual abuse of his other children; these messages ultimately led to the involvement of law enforcement and the defendant’s arrest and prosecution.The Garland County Circuit Court admitted the contested electronic messages into evidence, finding sufficient authentication through the testimony of the recipients. The court also allowed the defendant’s other daughter to testify to similar abuse under the “pedophile exception” to Arkansas Rule of Evidence 404(b), determining the testimony was more probative than prejudicial. The defendant moved for a continuance after being charged with additional sexual offenses days before trial, but the circuit court denied the motion, finding he was able to assist his counsel. After conviction, the court sentenced him to life in prison.On appeal to the Supreme Court of Arkansas, the defendant challenged the sufficiency of the evidence, the admission of the electronic messages and other-acts testimony, the denial of the continuance, and the constitutionality of his life sentence. The Supreme Court of Arkansas affirmed the conviction and sentence. It held that substantial evidence supported the jury’s finding that the defendant was in a position of authority over the victim as required by statute; the circuit court did not abuse its discretion in its evidentiary rulings or in denying the continuance; and the life sentence for child rape was not unconstitutional under either the Eighth Amendment or the Arkansas Constitution. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law