Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Petitioner was found guilty of capital murder and first-degree battery. Petitioner was sentenced to life imprisonment without parole. Thereafter, Petitioner filed four successive petitions with the Supreme Court seeking to reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of error coram nobis. The first three petitions were denied, and the fourth petition was dismissed as an abuse of the writ because it raised grounds that the Court had already addressed when it considered an earlier petition. Now before the Court was Petitioner’s fifth petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the writ, holding (1) Petitioner failed to state a ground for the writ; and (2) Petitioner failed to act with due diligence in bringing his claims. View "Grant v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. Appellant was sentenced as a habitual offender to life imprisonment without parole. The Supreme Court affirmed. 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 this case. The petition was denied. Now before the Supreme Court was Appellant’s second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the writ, holding that Appellant failed to state a ground within the four categories under which a writ of error coram nobis is proper. View "Gardner v. State" 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, kidnapping, and aggravated assault. Appellant was sentenced to life imprisonment for the murder conviction. Appellant later filed a petition for a writ of habeas corpus, arguing that the judgment in his case was illegal on its face because the trial court lacked subject-matter jurisdiction to sentence him to life imprisonment for the first-degree murder conviction. The circuit court declined to grant a writ of habeas corpus on the allegations raised by Appellant. The Supreme Court affirmed, holding that Appellant offered no grounds on which it could be said that the trial court lacked jurisdiction in his criminal case. View "Williams v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of four counts of aggravated robbery, three counts of misdemeanor theft of property, and one count of felony theft of property. The court of appeals affirmed. Appellant later filed in the Supreme Court two petitions to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the petitions because they either did not state a ground for the writ or were without merit. Appellant subsequently filed a third coram-nobis petition. The Supreme Court dismissed the petition, holding that his successive application for coram-nobis relief was an abuse of the writ because he alleged no fact sufficient to distinguish his claims in the instant petition from the claims in the first or second. View "Hutcherson v. State" on Justia Law

Posted in: Criminal Law
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Appellant submitted to the circuit court a petition for habeas corpus relief and asked the court for permission to proceed in forma pauperis. The circuit court denied the in forma pauperis petition, but the order was not file marked. Appellant appealed the denial of his petition to proceed in forma pauperis and tendered an appeal record to the clerk of court, but the record was rejected because it lacked a file-marked copy of the order from which Appellant appealed. Appellant subsequently filed a motion for rule on clerk. The Supreme Court granted the motion, holding that because the circuit court refused to file mark the order denying the in forma pauperis petition, Appellant demonstrated good cause for failure to perfect his appeal. View "Halfacre v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of first-degree felony murder. Defendant was sentenced to life in prison without parole. On appeal, Defendant’s counsel filed a no-merit brief asserting that there were no nonfrivolous arguments to be made on appeal and a motion to withdraw. The Supreme Court affirmed the conviction and granted counsel’s motion to withdraw, holding that none of the adverse rulings against Defendant provided meritorious grounds for reversal and that there were no other nonfrivolous arguments for an appeal. View "Felty v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of first-degree murder and arson. The trial court sentenced Defendant to life imprisonment. The Supreme Court affirmed, holding (1) Appellant’s arguments that the trial court erred by denying his motions for directed verdict were not preserved for appellate review; and (2) Appellant’s claim that the trial court erred by allowing witnesses to testify as to statements made to them by the deceased about her fear of Appellant and about his prior physical abuse of her was without merit, as the statements were nontestimonial and were not subject to the Confrontation Clause. View "Dickey v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Petitioner was found guilty of capital murder, attempted first-degree murder, and two counts of use of a firearm in the commission of a felony. 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 his petition, Petitioner made claims of ineffective assistance of counsel, insufficiency of the evidence, trial error, and mental incompetence. The Supreme Court denied the petition, holding that Petitioner’s claim of mental incompetence was unavailing and that the remainder of Petitioner’s allegations were outside the scope of a coram-nobis petition. View "Davis v. State" on Justia Law

Posted in: Criminal Law
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After a third jury trial, Appellant was found guilty of aggravated robbery. Appellant was sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging, inter alia, that he received ineffective assistance of counsel and that, although he was twenty-one years old at the time the offense was committed, he should have been treated the same as a juvenile. The circuit court dismissed Appellant’s petition. The Supreme Court affirmed, holding that Appellant’s claims were either outside the purview of a habeas corpus proceeding or without merit. View "Allen v. Kelley" on Justia Law

Posted in: Criminal Law
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Appellant was charged with several offenses for allegedly abusing his pregnant girlfriend and her son. The district court entered a no contact order and set bail at $25,000 cash or surety. Appellant posted bond and was released. The State subsequently moved to revoke Appellant’s release status and increase his bail on the grounds that he had violated the no contact order. After issuing a bench warrant, the circuit court set bail at $300,000 cash. Appellant filed a petition for writ of certiorari, arguing that Arkansas does not allow cash-only bail and that his bail was excessive. The Supreme Court denied the petition, holding (1) the Arkansas Constitution permits cash-only bail; and (2) because Appellant has pled guilty to several charges, the issue of excessive bail has become moot. View "Trujillo v. State" on Justia Law

Posted in: Criminal Law