Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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

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

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

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

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

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