Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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

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

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

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