Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of possession of methamphetamine, being a felon in possession of a firearm, and simultaneous possession of drugs and firearms. The court of appeals affirmed Appellant’s convictions and sentences. Appellant subsequently filed a timely postconviction petition alleging that the trial court was biased and that his two attorneys failed effectively to represent him. The trial court denied relief. The Supreme Court affirmed, holding (1) under Strickland v. Washington, Appellant failed to establish that he was prejudiced by his attorneys’ performance; and (2) the trial court did not err when it denied Appellant’s claim for postconviction relief without holding an evidentiary hearing. View "Stover v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder ad sentenced to death. The jury sentenced Appellant to death. The Supreme Court affirmed on appeal, holding (1) the circuit court did not err in denying an instruction on the extreme-emotional-disturbance formulation of manslaughter, as there was no rational basis to warrant an instruction of manslaughter; (2) the circuit court did not err by denying Appellant access to certain Arkansas Department of Correction records, as Appellant failed to meet the requirements of Ark. R. Crim. P. 17.4; and (3) no reversible error was determined to exist under Ark. Sup. Ct. R. 4-3(i) or Ark. R. App. P.-Crim. 10(b). View "Johnson v. State" on Justia Law

After a bench trial, Appellant was found guilty of internet stalking of a child and sentenced to 240 months’ imprisonment. The court of appeals affirmed. After the court of appeals’ mandate was issued, Appellant filed in the trial court a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The original petition was not properly verified. The trial court nonetheless held a hearing on the petition and denied it. The Supreme Court dismissed Appellant’s appeal without reaching its merits on the grounds that the petition filed in the trial court was subject to dismissal because Appellant did not comply with Rule 37.1(c) because he failed to file a properly verified petition within the time allowed by the Rule. View "Hendrix v. State" on Justia Law

Appellant filed an application for in-forma-pauperis status. Because the circuit court denied Appellant’s in-forma-pauperis petition, the circuit court would not file mark the relevant pleadings until Appellant paid the assessed fees. Instead of paying the fees, Appellant appealed. The clerk of the Supreme Court rejected the record tendered on appeal because it lacked a file-marked copy of the order denying Appellant’s application for in-forma-pauperis status. Appellant then filed a motion for rule on clerk. The Supreme Court granted Appellant’s motion for rule on clerk and remanded the record with directions for the circuit court to submit all relevant pleadings properly file marked and certified by the circuit clerk. When the circuit court returned the record to the Supreme Court, the relevant documents were stamped “received” rather than “filed.” The Supreme Court issued an order to show cause why the circuit clerk should not be held in contempt for failing to comply with the Supreme Court’s unambiguous direction to provide a record that was file marked in accordance with Administrative Order 2(b)(2). View "Halfacre v. Kelley" on Justia Law

After a jury trial, Defendant was convicted of rape. Defendant was sentenced to ten years in prison. The court of appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief arguing that he received ineffective assistance of counsel because his defense counsel failed to object to testimony that allegedly bolstered the victim’s credibility. The circuit court denied Defendant’s claim, concluding that defense counsel’s failure to object was based on trial strategy and that his performance was not deficient. The Supreme Court affirmed, holding that the circuit court did not err in finding that counsel’s failure to object was based on trial strategy. View "Fukunaga v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. Appellant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant later filed a pro se application for writ of certiorari arguing, inter alia, that his sentence was illegal because he was found guilty of capital murder with aggravated robbery as the underlying felony, and aggravated robbery did not specifically appear as a lesser-included offense to capital murder in the capital-murder statute at the time he committed the offenses. The trial court denied Appellant’s petition. The Supreme Court affirmed, holding that Appellant failed to show that he was entitled to relief for the writ of certiorari to issue. View "Burgie v. State" on Justia Law

After a jury trial, Appellant was found guilty of arson. Appellant was sentenced as a habitual offender to 144 months’ imprisonment. The court of appeals affirmed. Appellant later filed a pro se petition for writ of habeas corpus, arguing that the trial court lacked jurisdiction in his case and that the judgment was invalid on its face because the judgment-and-commitment order was signed by a different judge than the judge who presided over his trial and did not appear in the official record for the case. The Supreme Court affirmed, holding that neither Ark. Code Ann. 16-10-101(b)(1) nor Arkansas Supreme Court Administrative Order No. 16(1) invalidated the judgment-and-commitment order and deprived the trial court of jurisdiction under the circumstances of this case. View "Booth v. Kelley" on Justia Law

After a jury trial, Appellant was convicted of three counts of rape. Appellant was sentenced to consecutive terms of imprisonment of life, fifty years, and fifty years. Appellant appealed, contending that the trial court committed a speedy trial violation and did not follow the strict dictates of Ark. R. Crim. P. 28.3(b)(1). The Supreme Court affirmed, holding that Appellant’s trial date was well within the one-year period for a speedy trial, as the State met its burden to prove that any delay was excludable for speedy-trial purposes, and therefore, there was no speedy-trial violation in this case. View "Carter v. State" on Justia Law

After a jury trial, Appellant was convicted of kidnapping, rape, and aggravated robbery. Appellant was sentenced to three terms of life imprisonment. The Supreme Court affirmed on direct appeal, holding (1) Appellant’s arguments that the circuit court erred in denying his motions for directed verdict because the State provided sufficient evidence to find him guilty of kidnapping, rape, and aggravated robbery were not preserved for the Court’s review; and (2) the circuit court did not err when it denied Appellant’s motion for mistrial on the grounds that testimony by a law enforcement officer constituted an improper comment on Appellant’s silence and amounted to Doyle violations. View "Sylvester v. State" on Justia Law

After a jury trial, Appellant was convicted of kidnapping, rape, and aggravated robbery. Appellant was sentenced to three terms of life imprisonment. The Supreme Court affirmed on direct appeal, holding (1) Appellant’s arguments that the circuit court erred in denying his motions for directed verdict because the State provided sufficient evidence to find him guilty of kidnapping, rape, and aggravated robbery were not preserved for the Court’s review; and (2) the circuit court did not err when it denied Appellant’s motion for mistrial on the grounds that testimony by a law enforcement officer constituted an improper comment on Appellant’s silence and amounted to Doyle violations. View "Sylvester v. State" on Justia Law