Justia Arkansas Supreme Court Opinion Summaries

At a third trial Appellant was found guilty of aggravated robbery and sentenced to life imprisonment. Appellant later filed a pro se petition for writ of habeas corpus, alleging that trial counsel was ineffective, that he should not be subject to a sentence of life imprisonment without parole in accordance with Graham v. Florida, and that his trial counsel’s use of preemptory challenges to exclude white jurors and the State’s use of preemptory challenges to exclude black jurors violated his right to a trial by a fair and impartial jury. The Supreme denied relief, holding that Appellant did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Allen v. Kelley" on Justia Law

After a jury trial, Appellant was found guilty of forgery in the first degree and sentenced to 480 months’ imprisonment. The court of appeals affirmed and remanded to correct the sentencing order to reflect that Appellant was a habitual offender. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, raising some of the allegations that he raised in the trial court as grounds for reversal and raising new claims. Following a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err by not granting relief on Appellant’s claims. View "Williams v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and being a felon in possession of a firearm. Appellant subsequently filed two pro se motions in the trial court to dismiss counsel and to suppress a statement Appellant had given to a police officer. The trial court treated the two motions as one pro se petition for postconviction relief and denied relief. Appellant later filed in the trial court a pro se petition for relief under Ark. R. Crim. P. 37.1, raising some of the claims of ineffective assistance of counsel that he raised in his motion to dismiss counsel. Appellant also raised additional allegations for the first time. The trial court denied the petition, concluding that Appellant had already proceeded with a request for postconviction relief and thus was not entitled to a second proceeding. Appellant appealed and filed two motions related to the appeal. The Supreme Court dismissed the appeal and mooted the motions, holding that the trial court’s decision denying postconviction relief was not clearly erroneous. View "Toombs v. State" on Justia Law

Appellant was convicted of aggravated robbery and sentenced to life imprisonment. The Supreme Court affirmed both Appellant’s conviction and an order denying him postconviction relief pursuant to Ark. R. Crim. P. 37. Appellant later filed a petition for writ of habeas corpus. The circuit court denied his petition. The Supreme Court affirmed, holding (1) Appellant’s claims that the circuit court lacked jurisdiction to sentence him to life imprisonment were either without merit or not cognizable in a habeas proceeding; and (2) Appellant’s sentence, which was authorized by statute and found appropriate by the jury that imposed it, was not cruel or unusual. View "Philyaw v. Kelley" on Justia Law

Petitioner tendered for filing in the circuit court a pro se petition for leave to proceed in forma pauperis with respect to a petition for writ of mandamus and a proposed order granting leave to proceed in forma pauperis. The proposed order granting leave to proceed in forma pauperis was marked with the notation, “Petition Denied.” The appeal record was rejected by the Supreme Court clerk because it lacked a file-marked copy of the order from which Petitioner sought to appeal. Petitioner then tendered a motion for rule on clerk and a petition to proceed in forma pauperis, requesting that he be permitted to file the motion for rule on clerk without submitting the filing fee required to file such actions. The Supreme Court denied the petition, holding that because Petitioner had not alleged that a fundamental right is involved in his case, he was required to submit a fee to file the motion for rule on clerk. View "Penn v. Gallagher" on Justia Law

Appellant entered a guilty plea to first-degree murder and aggravated robbery and was sentenced to an aggregate sentence of 720 months’ imprisonment. Appellant later filed a petition for a writ of habeas corpus claiming that his sentence was illegal because it violated constitutional protections against double jeopardy. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not establish probable cause that he was illegally detained because he did not state facts in the petition to support his claim that the first-degree murder charge and the aggravated robbery charge were overlapping charges that violated double jeopardy. View "Holly v. Hobbs" on Justia Law

After a jury trial, Petitioner was convicted of multiple drug-related offenses and sentenced to 115 years’ imprisonment. The court of appeals affirmed. 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. As grounds for the writ, Petitioner alleged that the State violated the provisions of Brady v. Maryland in violation of his right to due process. The Supreme Court denied the petition, holding that Petitioner failed to show that the State withheld information or gave false, inconsistent, and ambiguous evidence in violation of Brady. View "Bond v. State" on Justia Law

Appellant entered guilty plea to a charge of being a felon in possession of a firearm. Appellant was sentenced to 180 months’ imprisonment. Appellant subsequently filed a pro se petition for a writ of habeas corpus. The trial court dismissed the petition on the ground that the petition should have been filed in the circuit court in the county where Appellant was incarcerated. The Supreme Court affirmed, holding that Appellant did not bring his habeas proceeding under Act 1780 of 2001 Acts of Arkansas, and therefore, the circuit court properly dismissed the petition, as it did not have authority to effect Appellant’s release from custody. View "Williams v. State" on Justia Law

The circuit court revoked Appellant’s suspended imposition of sentences. The Court of Appeals dismissed Appellant’s appeal, concluding that the notice of appeals was ineffective to confer appellate jurisdiction because the notice did not fairly and accurately inform the court of the order being appealed from. Appellant, by and through his attorney (Attorney), filed a motion for belated appeal. In the motion, Attorney admitted that it was his obligation to file an appropriate notice of appeal and candidly admitted fault. The Supreme Court granted the motion because Attorney was at fault for the appeal not being timely perfected. View "Todd v. State" on Justia Law

After a bench trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The Supreme Court reversed and dismissed Appellant’s conviction for capital murder, holding that the evidence could not sustain the charge of capital murder. Thereafter, the State did not refile a murder charge against Appellant. Rather, the State filed a “Motion for Court of Consider Lesser-Included Offenses.” The circuit court granted the motion, ruling that the evidence from the bench trial was sufficient to prove that Appellant committed first-degree murder. The court then sentenced Appellant as a habitual offender to forty years’ imprisonment for the first-degree murder. The Supreme Court reversed and dismissed, holding that because the conviction was reversed and dismissed, the circuit court did not have jurisdiction to hear the State’s “Motion for Court of Consider Lesser-Included Offenses.” View "Thornton v. State" on Justia Law