Justia Arkansas Supreme Court Opinion Summaries

In 2007, an individual was confronted by a store employee outside a Walmart in Hot Springs regarding stolen merchandise. The individual responded by brandishing a firearm. A jury in Garland County found him guilty of aggravated robbery, and he was sentenced to thirty years in prison. The Arkansas Court of Appeals later affirmed both his conviction and sentence.The individual subsequently filed a petition for writ of habeas corpus in the Chicot County Circuit Court, along with a request to proceed in forma pauperis. He argued that the criminal information in his case was not properly file-marked or accompanied by the required cover sheet, allegedly depriving the trial court of jurisdiction. The circuit court found that he had previously raised identical claims in an earlier petition and denied his request to proceed in forma pauperis, concluding that he failed to state a claim for which relief could be granted.The Supreme Court of Arkansas reviewed the circuit court’s denial of pauper status for abuse of discretion. The court held that the petitioner’s arguments regarding the lack of a file-mark and cover sheet did not implicate the facial validity of the judgment or the jurisdiction of the trial court, but rather amounted to claims of trial error. The court further found that the circuit court had subject-matter jurisdiction over the criminal case and that the petitioner failed to state a colorable cause of action for habeas relief. Accordingly, the Supreme Court of Arkansas affirmed the circuit court’s denial of the petition to proceed in forma pauperis. View "CARTER v. PAYNE" on Justia Law

The case concerns an individual who was convicted by a jury of first-degree murder following the stabbing death of his fiancée. He was sentenced as a violent-felony habitual offender to life imprisonment. After his conviction was affirmed on direct appeal, he filed a timely postconviction petition under Arkansas Rule of Criminal Procedure 37.1, alleging ineffective assistance of counsel. His claims included that his attorney failed to move for dismissal based on a speedy-trial violation, did not object to double hearsay in a voicemail admitted at trial, failed to obtain a transcript of the voicemail, did not properly advise him about a plea offer, requested a mental evaluation without his consent, and failed to investigate or obtain certain cell-phone records.The Pulaski County Circuit Court, Seventh Division, reviewed the petition. The court found that the periods of delay in bringing the defendant to trial were excludable under Arkansas law, so a speedy-trial motion would not have succeeded. The court also determined there was no evidence that the State possessed a transcript of the voicemail or that the defense was denied access to it, and that the defense had thoroughly cross-examined the relevant witness. The court found the record contradicted the claim that the defendant was misadvised about the plea offer, as the terms were explained in detail on the record. The court further concluded that the request for a mental evaluation was not outside the bounds of reasonable professional assistance and that there was no evidence it affected the outcome of the trial. Some claims were not preserved for review because the circuit court did not rule on them.The Supreme Court of Arkansas affirmed the circuit court’s denial of postconviction relief. The court held that the petitioner failed to demonstrate deficient performance by counsel or resulting prejudice as required by Strickland v. Washington, and that the circuit court’s findings were not clearly erroneous. View "NEAL v. STATE OF ARKANSAS" on Justia Law

A woman was found dead in her home in Booneville, Arkansas, after police were alerted by her children. The investigation quickly focused on her former boyfriend, who had recently ended a relationship with her and was seen with blood on his clothing the night of the incident. Evidence included a confession, DNA linking him to the scene, and testimony that he entered the home through a window, confronted the victim, and strangled her after a physical altercation. The victim’s vehicle was also taken and later found abandoned.The Logan County Circuit Court held a jury trial in December 2022. The jury convicted the defendant of first-degree murder, residential burglary, and theft of property, and imposed a sentence enhancement for committing murder in the presence of a child. The defendant was sentenced to life imprisonment plus additional consecutive terms and fines. During trial, the court denied the defendant’s motions for directed verdict on all charges and the sentence enhancement, denied motions to suppress his statements to law enforcement, admitted certain autopsy photographs over objection, and excluded some mitigating evidence at sentencing due to late disclosure.On appeal, the Supreme Court of Arkansas reviewed four main issues: sufficiency of the evidence, admissibility of custodial statements, admission of autopsy photographs, and exclusion of mitigating evidence. The court held that there was substantial evidence to support the murder conviction and that the defendant’s sufficiency arguments regarding burglary, theft, and the sentence enhancement were not preserved for review. The court found no error in admitting the defendant’s statements or the autopsy photographs, and it upheld the exclusion of the late-disclosed mitigating evidence. The Supreme Court of Arkansas affirmed the convictions and sentences. View "WEATHERFORD v. STATE OF ARKANSAS" on Justia Law

On December 25, 2022, Nathaniel Fort and his brother, Tarus Walker, went to Aaron Bruce’s apartment to confront him over an alleged assault involving Walker’s child. Walker was armed with an AK-47 rifle, and Fort carried two .40-caliber handguns. After Bruce left his apartment and joined his cousin, Patrick Ross, to discuss the matter, Walker shot Bruce, who fell to the ground. Fort then fired multiple shots into Bruce as he lay on the ground. The two men fled the scene in a vehicle matching the description of Fort’s mother’s car. Police recovered .40-caliber shell casings and bullets near Bruce’s body, and Bruce died at the scene from multiple gunshot wounds.The case was tried in the Miller County Circuit Court. During trial, the prosecution sought to admit Bruce’s autopsy report after the medical examiner who performed the autopsy became unavailable due to illness. Fort objected, arguing that the report required proper attestation and a supporting witness for admission. The circuit court overruled the objection, finding that Fort had waived his right to cross-examine by not subpoenaing a medical examiner or filing a notice of intent to cross-examine. The autopsy report was admitted, and Fort was convicted of capital murder and sentenced to life imprisonment.On appeal to the Supreme Court of Arkansas, Fort challenged the admission of the autopsy report, the denial of his right of allocution, and the sufficiency of the prosecutor’s short report of circumstances. The Supreme Court of Arkansas held that the circuit court erred in admitting the autopsy report without proper attestation, but found the error harmless due to overwhelming evidence of guilt and the cumulative nature of the report. The court also held that Fort’s allocution and report objections were unpreserved for appeal. The conviction and sentence were affirmed. View "FORT V. STATE OF ARKANSAS" on Justia Law

The case concerns William Coston, who was accused of sexually abusing a minor over several years, beginning when the victim was four years old. The abuse included multiple acts of rape, the introduction of controlled substances, and sexually grooming the child. Initially, Coston was charged with three counts of rape, but the State later amended the charges to include a total of ten counts of rape, one count of introduction of a controlled substance into the body of another person, and one count of sexually grooming a child. The evidence supporting these charges had been available to the defense throughout the discovery process.The Garland County Circuit Court presided over Coston’s jury trial in March 2024. Prior to trial, the State amended the criminal information to add the additional charges. Coston objected to the timing and number of the new charges, arguing that the amendment was arbitrary and created confusion, but he acknowledged that the evidence supporting the charges had been disclosed from the outset. He did not move to strike the amendment or request a continuance. The circuit court overruled his objection, noting that amendments to the information are permitted up to the point the case is submitted to the jury. After trial, Coston was convicted on all counts and sentenced to consecutive terms of imprisonment.On appeal to the Supreme Court of Arkansas, Coston argued that the circuit court abused its discretion by allowing the State to amend the information shortly before trial. The Supreme Court of Arkansas held that the amendment did not change the nature or degree of the offenses, as it merely added counts of the same offense, and that Coston was not unfairly surprised or prejudiced by the amendment. The court affirmed the circuit court’s decision, finding no prejudicial error. View "COSTON v. STATE OF ARKANSAS" on Justia Law

A man was convicted by a jury in Greene County, Arkansas, of five counts of rape involving a minor victim. The case involved evidence obtained from the defendant’s cell phone, including pornographic images, and testimony from the victim describing multiple incidents of sexual abuse, the use of sex toys, and exposure to child pornography. The victim’s account was corroborated by physical evidence, DNA analysis, and expert testimony from a sexual assault nurse examiner. The defendant denied the allegations, attributing the accusations to the victim’s desire to avoid blame for unrelated misconduct.After the conviction, the Arkansas Court of Appeals reversed and remanded, finding error in the admission of certain evidence. The State petitioned for review, which the Supreme Court of Arkansas granted, thereby reviewing the case as if it had been originally filed there. The defendant argued that the circuit court erred in denying his motion to suppress evidence from his cell phone, claiming the search warrant was facially deficient and lacked probable cause, and that the court improperly allowed cross-examination about prior orders of protection involving his girlfriend, in violation of evidentiary rules.The Supreme Court of Arkansas held that the circuit court did not err in denying the motion to suppress, finding that, under the totality of the circumstances, the officers acted in good faith and the warrant was not so deficient as to preclude reliance on it. The court also found that the circuit court abused its discretion in admitting evidence about the orders of protection, but concluded that the error was harmless because the evidence of guilt was overwhelming and the prejudicial effect was slight. The Supreme Court of Arkansas affirmed the convictions and vacated the opinion of the Court of Appeals. View "VASQUEZ v. STATE OF ARKANSAS" on Justia Law

The appellant was charged with capital murder following the shooting death of Zyrique “Zack” Geans in Stuttgart, Arkansas, on February 13, 2019. The prosecution alleged that the appellant, after an earlier altercation with the victim, discharged a firearm from a vehicle toward the victim, who was under a carport at his residence, resulting in the victim’s death. Multiple eyewitnesses testified that the appellant fired a handgun from a purple Camaro convertible toward the residence. Physical evidence, including shell casings and gunshot residue, supported the eyewitness accounts. The defense argued justification, claiming the appellant fired only after being shot at, and presented testimony to support this theory.The Arkansas County Circuit Court held a jury trial in January 2023. The jury found the appellant guilty of capital murder and of using a firearm to commit the offense. The court sentenced him to life imprisonment without parole, plus a fifteen-year firearm enhancement. The appellant challenged the sufficiency of the evidence, the voluntariness of his in-custody statements, and the completeness of the record for appellate review. The circuit court denied these motions, including the motion to suppress statements, finding that the appellant had knowingly and voluntarily waived his Miranda rights.On appeal, the Supreme Court of Arkansas reviewed the sufficiency of the evidence, the denial of the motion to suppress, and the adequacy of the record. The court held that substantial evidence supported the conviction, that the appellant’s waiver of Miranda rights was knowing, intelligent, and voluntary, and that the supplemented record was sufficient for appellate review. The court affirmed the conviction and sentence, finding no prejudicial error in the proceedings. View "HUDSON v. STATE OF ARKANSAS" on Justia Law

On January 14, 2023, a motorist, Arva Wilkerson, called 911 to report a speeding vehicle. After following the car and reciting its license plate, Wilkerson stated, “he is on to me.” Dylan Collins, the driver, noticed Wilkerson following him, pulled over, and Wilkerson stopped behind him. Without any communication, Collins exited his car, approached Wilkerson’s truck with a pistol, and fired thirteen shots into the vehicle. Collins then left the scene, destroyed the firearm, and did not contact authorities. Wilkerson died from his injuries the next day. Witnesses testified that Collins immediately fired upon Wilkerson without interaction and that Wilkerson’s gun was found later in a closed console.The case was tried in the Faulkner County Circuit Court. At trial, Collins claimed self-defense, stating he believed Wilkerson was reaching for a gun. However, evidence showed Collins did not see a weapon and did not speak to Wilkerson. Multiple witnesses corroborated that Wilkerson did not display a gun. The defense moved for a directed verdict, arguing the State failed to disprove justification, but the circuit court denied the motion, leaving the question for the jury. The jury convicted Collins of capital murder and firearm enhancement.On appeal to the Supreme Court of Arkansas, Collins challenged the sufficiency of the evidence regarding justification and the circuit court’s restriction of voir dire about burdens of proof. The Supreme Court of Arkansas held that substantial evidence supported the jury’s finding that Collins was not justified in using deadly force, as he was the initial aggressor and did not reasonably believe Wilkerson posed an imminent threat. The court also found no abuse of discretion in limiting voir dire to the relevant burden of proof. The judgment was affirmed. View "COLLINS v. STATE OF ARKANSAS" on Justia Law

The case concerns a man who, shortly after being released from prison, was staying at his grandmother’s house and had a contentious relationship with her husband. On the day of the incident, after an argument, he stabbed his grandmother’s husband more than twenty-five times in the kitchen, dragged the body outside, and threatened bystanders while holding the murder weapon. Forensic evidence indicated a violent struggle, with numerous defensive wounds on the victim. The defendant claimed self-defense, stating that the victim attacked him first, but his account was inconsistent and uncorroborated.The Desha County Circuit Court presided over the trial. Before trial, the defendant sought to exclude testimony from a neighbor who said the defendant had expressed a desire to harm the victim and burn down the house if his grandmother was not present. The court found this statement relevant to the defendant’s intent and admitted it. At trial, the defendant moved for a directed verdict, arguing only that the State had not proven he acted purposely, but did not specifically argue that the State failed to disprove self-defense. The jury found him guilty of first-degree murder and sentenced him to life in prison.The Supreme Court of Arkansas reviewed the case. It held that the sufficiency challenge regarding self-defense was not preserved for appeal because the defendant did not raise it with specificity at trial, as required by Arkansas Rule of Criminal Procedure 33.1. The court found that the evidence was sufficient to support a finding that the defendant purposely killed the victim, based on the nature and extent of the wounds and the defendant’s conduct. The court also held that the trial court did not abuse its discretion in admitting the neighbor’s testimony, as it was relevant and not unfairly prejudicial. The conviction was affirmed. View "MCDANIELS v. STATE OF ARKANSAS" on Justia Law

Timothy Clevenger was convicted of first-degree murder following the death of his wife, Margaret, who was found unresponsive and covered in blood in their home. The investigation revealed that Margaret had suffered multiple blunt-force head injuries, with evidence of a violent struggle and attempted cleanup at the scene. Clevenger was found with bloodstained clothing and injuries consistent with striking a person or object. His statements to police about his whereabouts and actions on the morning of the murder were contradicted by security footage and other evidence. The couple’s marriage was strained, and Clevenger was the sole beneficiary of a significant life insurance policy on Margaret.The Pulaski County Circuit Court presided over Clevenger’s trial. Clevenger moved to suppress evidence obtained from a search of his home, arguing that the search warrant was improperly issued and that the search violated procedural rules regarding nighttime searches. The circuit court denied the motion, finding no evidence of judicial bias and determining that the search complied with legal requirements. At trial, Clevenger also objected to the admission of certain evidence and witness testimony, but the court overruled or limited these objections, often noting that some arguments were not properly preserved.The Supreme Court of Arkansas reviewed the case on appeal. The court held that substantial evidence supported the conviction, including forensic evidence, inconsistencies in Clevenger’s statements, evidence of motive, and his attempt to evade arrest. The court found no error in the denial of the motion to suppress, concluding that the warrant was properly issued and the search was lawfully conducted. The court also determined that Clevenger’s evidentiary and procedural objections were either without merit or not preserved for review. The conviction and sentence were affirmed. View "Clevenger v. State" on Justia Law