Justia Arkansas Supreme Court Opinion Summaries

Appellant, an inmate incarcerated in the Arkansas Department of Correction, filed a pro se petition for writ of habeas corpus, which the circuit court denied. Appellant subsequently tendered a belated petition for rehearing at the same time that he filed a pro se motion for rule on clerk. Appellant asked the Supreme Court to direct its clerk to file the belated petition for rehearing, contending that the untimely petition should be filed because he placed a petition for rehearing in the mail prior to expiration of the deadline for filing. The Supreme Court denied the motion, holding that Appellant’s procedural default does not come within the parameters of the prison mailbox rule. View "Anderson v. Kelley" on Justia Law

Appellant was convicted of first-degree murder and committing a terroristic act. Appellant was sentenced as a habitual offender to a total term of life imprisonment plus fifteen years. The Supreme Court affirmed Appellant’s convictions and granted his attorney’s motion to withdraw as counsel, holding (1) there was sufficient evidence to support the convictions, and therefore, the circuit court did not err in denying Appellant’s motions for directed verdict; (2) the circuit court did not err in refusing to instruct the jury on reckless manslaughter; (3) the circuit court did not abuse its discretion in excluding evidence about the victim’s past involvement in drug transactions and his reputation as a drug dealer; and (4) Appellant’s pro se challenges were not properly raised on appeal. View "Starling v. State" on Justia Law

After a jury trial, Petitioner was found guilty of possession of a controlled substance and resisting arrest. 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 his petition, Petitioner alleged, inter alia, that the State withheld evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that Petitioner failed to establish that a Brady violation occurred in this case and that Petitioner's claims concerning the sufficiency of the evidence or the credibility of witnesses were not cognizable in coram-nobis proceedings. View "Rice v. State" on Justia Law

After a jury trial, Defendant was found guilty of three counts of rape and sentenced as a habitual offender to life imprisonment. Defendant later filed a pro se petition to correct an illegal sentence, arguing that the information violated the constitutional provisions against double jeopardy, the State violated Brady v. Maryland, and he was entitled to indictment by grand jury. The trial court denied relief. The Supreme Court affirmed, holding that the trial court’s decision was not clearly erroneous because Defendant did not meet his burden of demonstrating that the sentence was illegal. View "Williams v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder. Defendant was sentenced as a habitual offender to 720 months’ imprisonment. The court of appeals affirmed. Defendant later filed this pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. As grounds for the writ, Petitioner alleged that the State withheld witnesses and evidence from the defense at trial and that, under Martinez v. Ryan, the Court could consider his claims of ineffective assistance of counsel in a coram-nobis proceeding. The Supreme Court denied the petition, holding (1) Defendant did not demonstrate that the State violated Brady v. Maryland; (2) Defendant’s claims of ineffective assistance of counsel were not cognizable in a coram-nobis proceeding; and (3) even if Defendant had presented grounds sufficient to support issuance of the writ, his failure to act with due diligence would constitute good cause to deny the petition. View "Smith v. State" on Justia Law

Petitioner was convicted of one count of first-degree battery and one count of second-degree battery and sentenced to a total of 264 months’ imprisonment. Petitioner later filed a petition asking the Supreme Court to reinvest jurisdiction in the trial court so that he may file a petition for writ of error coram nobis. As his proposed grounds for the writ, Petitioner alleged that the State withheld evidence in violation of Brady v. Maryland. The Supreme Court denied relief, holding that Petitioner’s proposed attack on the judgment was without merit, and Petitioner had not stated a cause to support issuance of a writ of coram nobis. View "Moten v. State" on Justia Law

Appellant was convicted of possession of a Schedule III substance with the purpose to deliver, possession of a Schedule III substance, and possession of drug paraphernalia. Appellant appealed the denial of his motion to suppress evidence obtained as a result of a canine sniff conducted after he was pulled over for failing to use a turn signal. The Supreme Court reversed Appellant’s convictions and sentence, holding that the circuit court erred in denying Appellant’s motion to suppress where the canine sniff was conducted after Appellant’s continued detention that was conducted without reasonable suspicion. View "MacKintrush v. State" on Justia Law

Appellant pleaded guilty to rape and sexual assault in the second degree. Appellant was sentenced as a habitual offender to concurrent sentences of 120 months’ imprisonment for rape and 180 months’ imprisonment for second-degree sexual assault. Imposition of an additional 180 months’ imprisonment for second-degree sexual assault was suspended. The Supreme Court affirmed in part and remanded for resentencing in part, holding (1) Appellant’s ineffective-assistance-of-counsel claims and trial error claims were not cognizable in the error-coram-nobis proceedings; but (2) the suspended imposition of an additional 180-month sentence for sexual assault caused the ultimate sentence to exceed the statutory range allowed for the offense, rendering it illegal on its face. View "Ward v. State" on Justia Law

In two separate proceedings, Appellant was convicted of a number of drug-related charges. No appeal was taken from the judgments. Appellant later filed a petition in the trial court challenging the two judgments and filed a motion seeking to receive certain documents in the proceedings. The petition was couched in terms of extraordinary relief, but Appellant sought postconviction relief from his convictions. The trial court denied the motion and petition on the basis that Appellant should pursue his remedy in the Supreme Court. Appellant appealed to the Supreme Court and filed two motions in relation to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that the petition Appellant filed was not a petition on which the trial court could grant relief under Ark. R. Crim. P. 37. View "Nickels v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder and aggravated robbery. Defendant was sentenced to life without parole. The Supreme Court affirmed, holding that the circuit court did not err by (1) failing to grant Defendant’s motion for a directed verdict, as the evidence was sufficient to support the convictions; (2) denying Defendant’s motion to suppress a statement Defendant made to police while he was in custody; (3) failing to grant a mistrial due to the State’s allegedly improper remarks during closing, as the unobjected-to statement was not prejudicial; and (4) giving a nonmodel jury instruction. View "Conway v. State" on Justia Law