Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Petitioner was found guilty of three counts of rape and sentenced to 480 months’ imprisonment. The court of appeals affirmed. Petitioner later filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, as well as a petition seeking relief through a writ of error coram nobis or, alternatively, a writ of habeas crops. The trial court denied both petitions. The Supreme Court dismissed Petitioner’s appeal and declared moot Petitioner's two petitions he filed seeking an extension of time in which to file his brief, holding that Petitioner’s postconviction petition was not timely filed and that the circuit court lacked authority to grant relief under Petitioner’s second petition. View "Hunt v. State" on Justia Law

After a jury trial, Appellant was convicted of attempted first-degree murder, two counts of aggravated assault, and possession of a firearm. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, asserting that he was deprived of the effective assistance of counsel. The circuit court denied relief. Appellant appealed, repeating the allegations of error described in his petition for postconviction relief, but also raising new allegations of ineffective assistance of counsel. The Supreme Court affirmed, holding (1) Appellant's ineffective-assistance-of-counsel claims that were not raised before were not properly raised on appeal; and (2) the circuit court properly denied relief on Appellant's remaining claims. View "Frazier v. State" on Justia Law

Petitioner, an inmate, filed a pro se petition for writ of habeas corpus, challenging three judgments reflecting convictions for aggravated robbery and theft of property, sexual assault, and his status as a habitual offender for sentencing. In his habeas petition, Petitioner alleged that the judgments were facially invalid and that his due process rights were violated by the admission of certain evidence of other crimes during the guilt phase of his trial. The circuit court dismissed the petition. The Supreme Court dismissed Petitioner's appeal, denied his motion to supplement the record on appeal, and declared moot his motion for an extension of time in which to file his brief, holding that Petitioner failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Bunch v. State" on Justia Law

After a jury trial, Defendant was convicted of aggravated robbery, kidnapping, possession of a firearm, and related crimes. The court of appeals affirmed the convictions, ruling that they were supported by substantial evidence and that there was no speedy trial violation. Defendant later filed an Ark. R. Crim. P. 37.1 petition, claiming ineffective assistance of counsel, that the judgment of conviction was illegal on its face, and that his right to a speedy trial had been violated. The circuit court denied Defendant’s claims for postconviction relief. The Supreme Court affirmed, holding (1) Defendant’s speedy trial claim was not cognizable under Rule 37.1; (2) Defendant’s ineffective assistance of counsel claims were unavailing; (3) the circuit court did not abuse its discretion when it denied relief without first holding an evidentiary hearing; and (4) Defendant’s claim that the judgment of conviction was illegal on its face was not preserved for appeal. View "Barber v. State" on Justia Law

After a jury trial, Petitioner and a codefendant were found guilty of murder in the first degree committed in the perpetration of an attempted robbery. Both individuals were sentenced to life in prison. 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, alleging, inter alia, that the State withheld evidence from the defense at trial in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) there was no Brady violation because Petitioner did not show that there was any evidence withheld from the defense; and (2) Petitioner’s remaining allegations were not within the scope of a coram-nobis proceeding. View "Stewart v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder. The jury sentenced Defendant to death. The Supreme Court affirmed. Thereafter, Defendant filed a petition pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court granted Defendant a new sentencing hearing based on counsel’s admission that his performance had been inadequate. The court, however, denied Defendant relief on the basis that counsel should have presented a defense of mental disease or defect. The State appealed from the first finding, and Defendant appealed from the second finding. The Supreme Court (1) reversed on appeal, holding that the circuit court analyzed the case under a subjective legal standard rather than assessing counsel’s performance under an objective standard; and (2) affirmed on cross-appeal, holding that the circuit court did not err in denying relief based on counsel’s failure to present an affirmative defense. View "State v. Lacy" on Justia Law

After a jury trial, Defendant was found guilty of aggravated robbery. The jury found that Defendant was not armed with a deadly weapon for purposes of a firearm enhancement. Defendant was sentenced to ten years in the Arkansas Department of Correction. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant’s motion for directed verdict; and (2) the circuit court did not err in denying Defendant’s motion to set aside the guilty verdict on the aggravated robbery charge on the grounds that it was inconsistent with the acquittal on the firearm enhancement. View "Mercouri v. State" on Justia Law

Appellant pleaded guilty to the offense of failure to register as a sex offender and was placed on probation for a seventy-two-month period. Appellant’s probation was later revoked, and Appellant was sentenced to thirty-six months of imprisonment. Thereafter, Appellant pleaded guilty to several new crimes and was sentenced to 720 months’ imprisonment. Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 seeking to have the judgments in both cases declared void. While Appellant placed both docket numbers on the petition, the allegations contained in it pertained only to his most recent criminal case. The trial court dismissed the petition, concluding that the issues raised in the petition were without merit and that the Rule 37.1 petition was not timely filed. Appellant lodged an appeal from the order and filed motions for extension of time to file his brief. The Supreme Court dismissed the appeal, which rendered moot the motions, holding that, with respect to Appellant’s prior criminal case, the petition was untimely filed, and as regards Appellant’s most recent criminal case, the petition did not state a ground on which relief under Rule 37.1 could be properly granted. View "Engstrom v. State" on Justia Law

Petitioner filed a series of motions in the circuit court that challenged judgments in two criminal cases. The circuit court denied the motions. In both cases, Petitioner filed a notice of appeal that referenced the order denying the motion in one criminal case. The clerk of record declined to lodge the record because the notice of appeal was not timely as to any order contained in the record. Petitioner subsequently filed in the Supreme Court the first of three motions for belated appeal or rule on clerk and for appointment of counsel. The Supreme Court (1) denied the motions for belated appeal as to that part concerning Petitioner’s request to proceed with an appeal, holding that Petitioner failed to meet his burden to establish good cause for his failure to comply with the Court’s procedural rules; and (2) therefore, the parts of the motions concerning Petitioner’s request for counsel and the motions for use of the record and to supplement the record were moot. View "Dennis v. State" on Justia Law

Petitioner filed a petition for declaratory judgment and writ of mandamus seeking a declaratory judgment concerning the calculation of his parole eligibility date and a writ of mandamus directing certain state officers and employees to recalculate his parole eligibility date. The circuit court denied the petition. Petitioner filed a notice of appeal, but the clerk of court declined to lodge the record because the notice of appeal was not timely. Petitioner then filed this motion requesting permission to proceed with an appeal through rule on clerk or by belated appeal. The Supreme Court denied the motion, holding that Petitioner failed to meet his burden to establish good cause for his failure to file a timely notice of appeal. View "Davis v. Hobbs" on Justia Law