Justia Arkansas Supreme Court Opinion Summaries

In 2011, judgment was entered reflecting that Petitioner had entered a plea of guilty to two counts of forgery. In 2015, Petitioner tendered to the Supreme Court a certified copy of the 2011 judgment with his pro se motion for leave to proceed with a belated appeal of the judgment. The Supreme Court dismissed the judgment because it was not timely tendered to the Court and because the judgment was entered on a plea of guilty and Petitioner’s plea did not meet any of the exceptions that would allow for an appeal from the judgment. View "Wright v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder, with residential burglary as the underlying felony, and theft of property. Defendant was sentenced to life in prison without parole for capital murder and twenty years in prison for theft of property. Appellant later filed a petition for writ of habeas corpus in the circuit court. The circuit court denied relief on the grounds that Appellant failed to challenge the jurisdiction of the court and made his claims for the sole purpose of retrying his case. Now before the Supreme Court were Appellant’s motion for extension of time to file a brief and petition for writ of mandamus, which the Court treated as a motion to expedite. The Supreme Court dismissed the appeal and declared the motions moot, holding that it was clear from the record that Appellant could not prevail on appeal. View "Hinkston v. State" on Justia Law

When he was fifteen years old, Z.L. was charged as an adult of rape. An Extended Juvenile Jurisdiction (EJJ) adjudication order was entered, and Z.L. was committed to the Arkansas Division of Youth Services (DYS). When Z.L. was twenty-one, DYS released him, and Z.L.’s case was set for a hearing in the circuit court to consider imposition of an adult sentence. After a hearing, the circuit court entered an order in the juvenile division finding that Z.L.’s case should be transferred to the criminal division. A second juvenile order was subsequently entered finding that an adult sentence was appropriate. Z.L. was sentenced to twenty-five years in the Arkansas Department of Correction. Z.L. appealed, arguing that the circuit court lacked jurisdiction to impose an adult sentence because he had reached the age of twenty-one before the EJJ review hearing was scheduled and conducted and before the sentencing order was entered. The Supreme Court agreed and reversed and dismissed the case, holding that the circuit court lacked jurisdiction to conduct an EJJ review hearing and impose an adult sentence on Z.L. View "Z.L. v. State" on Justia Law

Appellant pled guilty to one count of sexual assault in the first degree and was sentenced to thirty years’ imprisonment. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that defense counsel was ineffective on seven separate grounds. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to assert that but for any alleged ineffectiveness on the part of counsel he would not have pleaded guilty and would have gone to trial; and (2) the circuit court did not clearly err in denying Appellant’s petition without holding an evidentiary hearing. View "Wood v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of delivery of a controlled substance. Appellant was sentenced as a habitual offender to an aggregate term of 360 months in prison. Appellant later filed a pro se petition for writ of habeas corpus seeking release from custody, contending that the trial court made a number of errors pertaining to whether evidence was admissible and that the evidence was insufficient to support the conviction. The circuit court denied relief, concluding that Appellant did not establish a ground in his petition for issuance of a writ of habeas corpus. The Supreme Court dismissed Appellant’s appeal, holding that Appellant failed to state a basis for the writ. View "Tucker v. State" on Justia Law

In 1990, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 1993, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 36.4. The trial court dismissed the petition on the ground that it was not timely filed. Appellant appealed, arguing that the petition was timely because he was entitled to the three-year limitations period under the former version of Ark. R. Crim. P. 37. The Supreme Court affirmed, holding that Appellant could not proceed under either remedy in a timely manner. In 2015, Appellant filed a “motion for a new trial or reduction of sentence under a belated Rule 36.4 motion for a new trial,” again arguing that he was entitled to proceed for postconviction relief under Rule 36.4. The trial court denied the motion. The Supreme Court dismissed the appeal, holding that Appelalnt did not show in his 2015 motion that there was a ground to permit a belated Rule 36.4 petition to be filed. View "Ray v. State" on Justia Law

Appellant entered a conditional plea of guilty to a charge of driving while intoxicated, sixth offense. Appellant appealed, arguing that his conviction violated the ex post facto clauses of the Arkansas Constitution and United States Constitution. This appeal presented an issue of first impression whether an appeal was allowed from Appellant’s conditional plea. The Supreme Court affirmed, holding (1) under the circumstances of this case, the Court has jurisdiction to consider the appeal; and (2) as to the merits, Appellant’s conviction does not violate the ex post facto clauses of the United States Constitution and Arkansas Constitution. View "Laymon v. State" on Justia Law

In 2008, Appellant was convicted of rape and sentenced to life imprisonment. Appellant later filed a petition for writ of habeas corpus, arguing that the sentence imposed was illegal because he was sentenced as a habitual offender without notice of the habitual-offender charge. The circuit court denied relief, concluding that Appellant failed to provide a meritorious ground for relief. The Supreme Court affirmed the order denying the habeas petition, holding that Appellant demonstrated no error in the circuit court’s holding that he did not provide in his petition meritorious grounds for the writ. View "Kelley v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery, theft of property, and possession of a defaced firearm. Appellant was charged as a habitual offender, and each conviction was enhanced by five years pursuant to Ark. Code Ann. 16-90-120. Appellant was sentenced to a total of fifteen years’ imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant’s motion for directed verdict regarding the theft of property charge, as the evidence was sufficient to support the conviction; and (2) Appellant failed to show that the firearm enhancements he received pursuant to section 16-90-120(a) were illegal. View "Hinton v. State" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery and misdemeanor theft of property. In a separate case, Petitioner was found guilty of being a felon in possession of a firearm, filing a false report with law enforcement, and misdemeanor fleeing. 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. The Supreme Court denied the petition, holding that Petitioner’s claims were either not cognizable in coram-nobis proceedings or without merit. View "Butler v. State" on Justia Law