Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Petitioner, who represented himself at trial with standby counsel, was convicted of aggravated robbery, terroristic threatening in the first degree, theft of property, and battery in the third degree. The Court of Appeals affirmed. Now before the Supreme Court was Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case. In his petition, Petitioner argued that he was not sane at the time he committed the offenses or at the time of trial. The Supreme Court denied the petition, holding (1) to the extent Petitioner was contending that his pretrial or standby counsel was ineffective, he did not state a ground for the writ; and (2) Petitioner did not establish any other basis on which the writ could be issued. View "Williams v. State" on Justia Law

Posted in: Criminal Law
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Appellant pleaded guilty to first-degree murder. Appellant was sentenced by a jury, and the jury sentenced Appellant to life imprisonment. The Supreme Court affirmed the sentence. Appellant later filed a pro se verified petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 arguing that he was denied effective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding that the trial court did not err when it denied Appellant’s multiple ineffective assistance of counsel claims, as Appellant failed to establish that his counsel was ineffective. View "Pedraza v. State" on Justia Law

Posted in: Criminal Law
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In 1994, Petitioner was convicted of first-degree murder, robbery, and burglary. In 2014, Petitioner filed a petition to correct an illegal sentence. The circuit court dismissed the petition as untimely. Petitioner subsequently filed in the Supreme Court the instant pro se motion for belated appeal of the circuit court’s order dismissing his petition, seeking to proceed with an appeal of the order despite his failure to file a timely notice of appeal. The Supreme Court denied the motion, as Petitioner did not meet his burden of demonstrating good cause for failing to conform to the procedural rules. View "O'Neal v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Petitioner was found guilty of rape. Petitioner was sentenced as a habitual offender to 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 in the case. In his petition, Petitioner asserted that the State violated his right to due process pursuant to Brady v. Maryland by concealing information from the defense. The Supreme Court denied the petition, holding that Petitioner’s allegations failed to establish that there was some material evidence withheld that would have prevented rendition of the judgment had it been known at the time of trial. View "Jordan v. State" on Justia Law

Posted in: Criminal Law
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Petitioner entered a negotiated plea to first-degree murder and received a sentence of 228 months’ imprisonment and an additional 120 months’ suspended imposition of sentence. Petitioner subsequently filed two pro se petitions for postconviction relief under Ark. R. Crim. P. 37.1. Both petitions were dismissed. When Petitioner tendered the record to appeal the second order, the clerk of court declined to lodge it because the notice of appeal was not timely filed. Petitioner now filed this pro se motion for belated appeal. The Supreme Court denied the motion, as Petitioner failed to demonstrate good cause to excuse his procedural default. View "Jackson v. State" on Justia Law

Posted in: Criminal Law
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Appellant pleaded guilty to rape and first-degree sexual assault and was sentenced to serve an aggregate terms of sixty years’ imprisonment. Appellant subsequently filed three petitions for writ of error coram nobis. The trial court denied the three petitions. The Supreme Court affirmed. In 2015, Appellant filed a petition for a writ of habeas corpus challenging the application of Ark. Code Ann. 5-4-501(c), a habitual offender statute, to his sentence. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err when it declined to grant a writ of habeas corpus on the allegations raised by Appellant. View "Morgan v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of murder in the first degree and burglary. Appellant was sentenced to life imprisonment for the murder conviction and a consecutive six years’ imprisonment for the burglary conviction. Appellant later filed a petition for a writ of habeas corpus, alleging that the judgment in his case was illegal on its face because it provided that the six-year term for burglary would not begin until expiration of the life sentence. The Supreme Court affirmed, holding that Appellant’s sentence was permitted by the sentencing statute in effect when he committed his offenses, and therefore, the circuit court did not err when it declined to grant a writ of habeas corpus on the grounds raised by Appellant. View "Smith v. Kelley" on Justia Law

Posted in: Criminal Law
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Appellant entered a negotiated plea of guilty to attempted first-degree murder and aggravated robbery and was sentenced to an aggregate term of 780 months’ imprisonment. Appellant later filed in the trial court a pro se petition for writ of error coram nobis, alleging ineffective assistance of counsel and that his guilty plea was coerced because his plea was the result of his mental state. The trial court denied the petition. The Supreme Court affirmed, holding (1) the ineffective-assistance-of-counsel allegations did not establish a ground for the writ; and (2) Petitioner failed to present facts sufficient to demonstrate that there was information not known at the time of trial that could have established that he was insane and incompetent to proceed. View "Oliver v. State" on Justia Law

Posted in: Criminal Law
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After a bench trial, Appellant was found guilty of first- and second-degree battery. Appellant appealed, arguing that he was denied the right to a trial by jury. The court of appeals affirmed, holding that Appellant knowingly, intelligently, and voluntarily waived that right. Appellant later filed a petition for a writ of habeas corpus and for declaratory judgment, arguing that the trial court lacked jurisdiction in his case because he was not afforded a trial by jury. The circuit court dismissed the petition with respect to the claims for declaratory judgment and denied the petition as to the claims for a writ of habeas corpus. Appellant appealed the denial of his petition for habeas corpus. The Supreme Court affirmed, holding that, as Appellant failed to establish that the judgment was invalid on its face or that the trial court lacked jurisdiction in his case, he did not state a ground for a writ of habeas corpus. View "Moten v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of kidnapping, rape, and first-degree battery. Appellant was sentenced as a habitual offender to consecutive terms of imprisonment for life, life, and forty years. The Supreme Court affirmed. Appellant later filed a petition for writ of habeas corpus, arguing, among other things, that the judgment was illegal on its face because the trial court lacked authority to sentence him to terms of life imprisonment because he was under the age of twenty-one when he committed the offenses. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Graham v. Florida did not apply to Appellant because he did not allege that he was under the age of eighteen when he committed the offenses; and (2) as to Appellant’s remaining claims, he did not establish the facial invalidity of the judgment in his case or the lack of jurisdiction by the trial court, and therefore, he did not show that he was entitled to relief. View "Mitchell v. Kelley" on Justia Law

Posted in: Criminal Law