Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of one count of capital murder in one case and one count of capital murder in another case. Appellant was sentenced to two consecutive terms of life imprisonment without parole. Appellant later filed a petition and a successive petition asking the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Court denied both petitions. Appellant then filed a pro se Ark. R. Crim. P. 37.1 petition. The trial court denied the petition on the ground that it was not timely filed. The Supreme Court dismissed Appellant’s appeal, holding that the petition was untimely. View "Rhoades v. State" on Justia Law

After a jury trial, Appellant was found guilty of one count of capital murder in one case and one count of capital murder in another case. Appellant was sentenced to two consecutive terms of life imprisonment without parole. Appellant later filed a petition and a successive petition asking the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Court denied both petitions. Appellant then filed a pro se Ark. R. Crim. P. 37.1 petition. The trial court denied the petition on the ground that it was not timely filed. The Supreme Court dismissed Appellant’s appeal, holding that the petition was untimely. View "Rhoades v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and theft of property. Appellant was sentenced to an aggregate term of thirty-five years’ imprisonment. Appellant later filed a petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-201 in the Jefferson County Circuit Court, alleging that untested DNA evidence entitled him to the writ. After noting that Appellant was incarcerated in Hot Spring County, Arkansas, the circuit court dismissed the petition for lack of jurisdiction. The Supreme Court reversed, holding that because Appellant was convicted in Jefferson County, Appellant properly filed his petition in the Jefferson County Circuit Court. Remanded. View "Makkali v. Kelley" on Justia Law

In two separate cases, Appellant pleaded guilty to first-degree murder and aggravated assault and to furnishing prohibited articles into a correctional facility. Appellant later filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the first case. The petition, however, raised issues pertaining to both cases. The trial court declined to issue the writ. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying the petition for writ of error coram nobis where the petition did not state a cognizable claim for relief. View "Gonder v. State" on Justia Law

Appellant pled guilty to one count each of first-degree murder, aggravated assault, and attempting to furnish a prohibited article. Appellant later filed an amended civil complaint against the deputy prosecutor, alleging that the prosecutor had misstated facts during Appellant’s plea hearing and withheld victim-impact statements. Appellant requested injunctive relief in his amended complaint. The trial court concluded that the complaint was barred by absolute prosecutorial immunity, sovereign immunity, the statute of limitations, and that the action was governed by Ark. R. Crim. P. 37.1. The Supreme Court affirmed, holding that the circuit court did not err in concluding that Appellant’s amended complaint was governed by the requirements of Rule 37 and, as such, was an untimely, successive petition for postconviction relief that raised claims that were procedurally barred. View "Gonder v. Spain" on Justia Law

Petitioner pleaded guilty to four counts of rape and was sentenced to a total of 720 months in prison. Petitioner later filed in the circuit court an Ark. R. Crim. P. 37.1 petition. The trial court denied Petitioner’s Rule 37.1 petition as untimely. Petitioner later filed a motion for belated appeal, contending that the circuit clerk erred by not file-marking his Rule 37.1 petition. The Supreme Court treated the motion for belated appeal as a motion for rule on clerk to perfect the appeal and remanded the matter to the trial court with direction that the circuit clerk determine the correct file-mark date for Petitioner’s Rule 37.1 petition. Upon the filing of the Rule 37.1 petition, the trial court should determine whether it can reach the merits of the Rule 37.1 petition. View "Cook 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 petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, raising two claims of error in support of his petition. The trial court denied the petition. Appellant lodged an appeal in the Supreme Court and filed four motions related to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that Appellant did not show that his sentence was illegal and, therefore, was not entitled to relief under section 16-90-111. View "Burgie v. State" on Justia Law

Appellant brought a criminal charge against Appellee, alleging that Appellee had engaged in sexual indecency with a child, in violation of Ark. Code Ann. 5-14-110(a)(4)(C). After a jury trial, the circuit court directed a verdict in Appellant’s favor. The State appealed, challenging the trial court’s interpretation of the criminal statute. Specifically, the State argued that the circuit court did not err in determining what is meant by the phrase “another person” in section 5-14-110(a)(4)(C). The Supreme Court accepted the appeal and affirmed the circuit court’s decision, holding that the circuit court did not err in its determination of what is meant by the phrase “another person” in the criminal statute. View "State v. Coble" on Justia Law

In 2000, Appellant was convicted of capital murder and sentenced to death. Thereafter, Appellant filed a waiver of appeal and of postconviction review. The Supreme Court affirmed Appellant’s waiver of his right to appeal, as well as his conviction and sentence. The circuit court then held a hearing pursuant to Ark. R. Crim. P. 37.5. Appellant again waived his right to seek postconviction relief. Appellant later filed an untimely Rule 37.5 petition and an amended postconviction petition. The circuit court denied relief. The Supreme Court concluded that a more recent competency evaluation of Appellant was required to adequately determine his competency to elect execution and waive postconviction remedies. After Appellant was evaluated and after a hearing, the circuit court concluded that Appellant was competent and had the capacity to waive his postconviction relief. Accordingly, the circuit court dismissed Appellant’s petition for postconviction relief. The Supreme Court reversed, holding that the circuit court erred in finding that Appellant was competent to waive his postconviction remedies. Remanded for postconviction proceedings under Rule 37.5. View "Roberts v. State" on Justia Law

After a jury trial, Appellant was found guilty of possession of cocaine with intent to deliver. Appellant was sentenced as a habitual offender to 240 months’ imprisonment. The court of appeals affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging, in essence, that there was insufficient evidence put forward at trial to sustain the judgment. The circuit court dismissed the petition, concluding that Appellant had not stated a ground for the writ. The Supreme Court affirmed, holding that Appellant failed to state a ground for the writ in his petition, and therefore, relief was properly denied. View "Lovett v. Kelley" on Justia Law