Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of three counts of aggravated robbery and one count of theft of property. The Supreme Court affirmed Appellant’s convictions and sentences on appeal. Thereafter, Appellant filed a petition for postconviction relief, arguing, among other claims, that his arrest was based on insufficient evidence, the trial court committed error during trial, his right to a speedy trial was violated, counsel provided ineffective assistance, and the prosecutor engaged in impermissible misconduct. The trial court rejected Appellant’s claims. The Supreme Court affirmed, holding that Appellant’s claims were either not properly before the Court, without merit, or not grounds for postconviction relief. View "Chatmon v. State" on Justia Law

Appellant pleaded guilty to aggravated robbery and was sentenced to 300 months’ imprisonment. Appellant later filed a pro se petition for writ of error coram nobis, alleging that his trial counsel coerced him into a guilty plea. The petition was denied. The Supreme Court affirmed, holding that while Appellant couched his claim in terms of a coerced guilty plea, the actual basis for his claim was ineffective assistance of counsel. Because ineffective assistance of counsel claims are cognizable in error-coram-nobis proceedings, Appellant did not state a ground for the writ, and therefore, the trial court did not err in denying error-coram-nobis relief. View "Biggs v. State" on Justia Law

After a jury trial, Petitioner was convicted of two counts of rape of a child and sentenced to two consecutive terms of life imprisonment. The Supreme Court affirmed. Now before the Court was Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and related motions. In support of his petition, Petitioner alleged that the State violated Brady v. Maryland by withholding evidence to the prejudice of Petitioner. The Supreme Court denied the petitions and declared the motions moot, holding that Petitioner failed to assert a ground sufficient to entitle him to coram-nobis relief. View "Berger v. State" on Justia Law

Appellant was convicted of kidnapping, aggravated residential burglary, and other offenses. Appellant was sentenced to fifty-two years’ imprisonment, which included a firearm enhancement. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The circuit court denied relief without holding a hearing. The Supreme Court affirmed, holding (1) Appellant did not establish that his trial counsel was ineffective for failing to pursue and actual-innocence defense where Appellant’s counsel actually pursued an actual-innocence defense at trial; (2) Appellant failed to demonstrate prejudice due to trial counsel’s failure to move for a change of venue; (3) Appellant’s sentence for employing a firearm in the commission of an offense was not void as the result of ineffective assistance of trial counsel; and (4) considering the totality of the evidence, the circuit court did not clearly err in denying Appellant’s request for an evidentiary hearing. View "Van Winkle v. State" on Justia Law

After a jury trial, Appellant was found guilty of possession of cocaine with intent to deliver, possession of methamphetamine with intent to deliver, and maintaining a drug premises. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging two instances of ineffective assistance of counsel. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the circuit court did not err in ruling that trial counsel was not ineffective for failing to object to certain comments made by the prosecutor during closing argument; and (2) the circuit court’s findings regarding Appellant’s argument that trial counsel was ineffective for failing to make a motion to dismiss for lack of a speedy trial and for failing to make an adequate record that the time for speedy trial had run before the trial started were insufficient for the Court’s review. View "Turner v. State" on Justia Law

In 2011, Appellant pleaded guilty to multiple felony offenses and was sentenced as a habitual offender to 240 months’ imprisonment. Petitioner later filed a petition to correct an illegal sentence, which the trial court denied. On appeal, the Supreme Court treated the petition as a claim for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and dismissed the appeal because the petition was untimely. Thereafter, Petitioner filed a pleading styled “motion for belated Rule 37.1” alleging that his guilty plea was the result of ineffective assistance of counsel. The trial court dismissed the request for postconviction relief as untimely filed. The Supreme Court dismissed Appellant’s appeal, holding that the trial court correctly determined that the petition was not timely filed. View "Tolliver v. State" on Justia Law

After a jury trial in 1993, Petitioner was found guilty of murder in the first degree. Petitioner was sentenced to life imprisonment. In 2016, Petitioner filed his third petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In the petition, Petitioner reiterated claims raised in a second coram-nobis petition that the Supreme Court denied in 2015. The Supreme Court dismissed the petition, holding that the petition was an abuse of the writ because Petitioner had raised essentially the same claims in his second petition. View "Swanigan v. State" on Justia Law

After a second jury trial, Appellant was convicted of four counts of rape. The court of appeals affirmed. Appellant subsequently filed an Ark. R. Crim. P. 37 petition, alleging ineffective assistance of counsel. Appellant’s petition contained three allegations of deficient performance during the second jury trial. The circuit court denied the petition without a hearing, concluding that the first allegation was conclusory and the remaining allegations were matters of trial strategy and could not form the basis for postconviction relief. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the circuit court correctly found that the first allegation could not form the basis for postconviction relief; but (2) Appellant’s second and third claims for relief based on ineffective assistance of counsel were colorable claims. Remanded for a hearing on Appellant’s second and third claims. View "Sandrelli v. State" on Justia Law

In two separate cases, Appellant pleaded guilty to several offenses, including aggravated robbery and theft. Appellant filed a timely petition pursuant to Ark. R. Crim. P. 37 alleging that his convictions were the result of ineffective assistance of his counsel, Kathryn Hudson. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not commit clear error in denying Appellant’s petition, as Appellant failed to offer sufficient proof that a State plea offer existed that counsel failed to communicate and failed to explain how certain conduct on the part of counsel intimidated him into pleading guilty. View "Robinson v. State" on Justia Law

Appellant was found guilty of eleven counts of rape of a victim who was less than fourteen years of age and one count of interference with custody. Appellant was sentenced to consecutive life sentences for each count of rape. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging ineffective assistance of trial counsel. The trial court denied relief. The Supreme Court affirmed, holding (1) the trial court’s findings on the claims raised in the petition were adequate for review; and (2) the trial court did not clearly err in finding that Appellant failed to identify specific acts or omissions that would overcome the presumption that counsel was effective, nor did Appellant provide factual substantiation for his claims of prejudice. View "Pigg v. State" on Justia Law