Justia Arkansas Supreme Court Opinion Summaries

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

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