Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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