Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

Posted in: Criminal Law