Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Petitioner entered a negotiated plea of guilty to charges in two criminal cases. Five years later, Petitioner filed an amended petition for writ of error coram nobis in the circuit court seeking to amend a previously filed petition for the writ that challenged his convictions in one of the two cases. Less than two months later, Petitioner filed three pro se petitions in the Supreme Court seeking (1) a writ of mandamus to compel the circuit judge to conduct a hearing on the amended petition for writ of error coram nobis, (2) to supplement his petition for the writ of mandamus, and (3) an order that the circuit court proceedings be held in abeyance. The Supreme Court denied the petitions for the writ of mandamus and to supplement the petition for the writ of mandamus and declared the petition seeking a stay moot, holding that Petitioner failed to present an issue that satisfied the factors necessary for issuance of a writ of mandamus. View "Gonder v. Glover" on Justia Law

Posted in: Criminal Law
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After a bench trial, Defendant was convicted of negligent homicide and inadequate insurance during an accident and sentenced to six months in the county jail. The Supreme Court affirmed in part and reversed and dismissed in part, holding (1) the circuit court erred in denying Defendant’s motion to dismiss the negligent-homicide charge because the State failed to present sufficient evidence of criminal negligence; and (2) the circuit court did not err in denying Defendant’s motion to dismiss the charge of inadequate insurance because the State presented sufficient evidence that Defendant failed to carry adequate insurance at the time of the accident. View "Gill v. State" on Justia Law

Posted in: Criminal Law
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Appellant, a prisoner, filed a petition for declaratory judgment and for writ of mandamus seeking to have the circuit court declare Ark. Code Ann. 16-93-609 unconstitutional, declare his commitment invalid, and order the director of the Arkansas Department of Correction (ADC) to recalculate his parole eligibility. The circuit court dismissed the matter, finding that Appellant alleged no meritorious basis for the relief he sought. The Supreme Court affirmed, holding (1) the circuit court did not err in failing to declare that the ADC’s calculation of Appelalnt's parole eligibility was in error and failing to order the ADC to recalculate his parole eligibility; and (2) Appellant presented no meritorious basis in challenging the ADC’s interpretation of section 16-93-609 and its application to calculate his parole eligibility. View "Wright v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was convicted of residential burglary and rape. Appellant appealed, arguing that the circuit court erred in excluding evidence of DNA from semen samples found on the victim’s bedsheet and pillow that were inconsistent with his DNA. Appellant asserted that the evidence was relevant to his theory of misidentification and that the probative value of evidence of another person’s semen at the crime scene outweighed any prejudice to the victim. The Supreme Court affirmed, holding that the circuit court did not commit a manifest abuse of discretion in denying Appellant’s motions to admit such evidence pursuant to the rape-shield statute. View "Thacker v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of one count of rape and four counts of possession of drug paraphernalia. The convictions were affirmed on appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37. The circuit court denied the petition. Appellant then filed a pro se notice of appeal, and his counsel filed a notice of appeal. The record was not timely lodged with the clerk of court. Appellant’s counsel filed a motion for rule on clerk, admitting that he did not tender the record in this case. The Supreme Court granted the motion, as there was error on counsel’s part in failing to timely lodge the record. View "McCulley 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, aggravated residential burglary, attempted kidnapping, first-degree battery, and aggravated assault. Appellant was sentenced to two terms of life imprisonment. After the parties had filed their respective briefs on appeal, Appellant’s counsel filed a third motion to withdraw as counsel. The Supreme Court affirmed the convictions and granted counsel’s motion to withdraw, holding (1) none of the rulings adverse to Appellant presented grounds for reversal; and (2) Appellant’s pro se points on appeal offered no ground for reversal. View "Her v. State" on Justia Law

Posted in: Criminal Law
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Appellant entered a guilty plea to first-degree murder and was sentenced to 480 months’ imprisonment. Appellant later filed a pro se petition for writ of habeas corpus. The circuit court denied the petition. Appellant appealed, alleging that he was denied his right to counsel during questioning sessions with law enforcement officers, that the trial court failed to establish a factual basis for his plea, and that the circuit court erroneously found his habeas corpus petition constituted a strike under Ark. Code Ann. 16-68-607. The Supreme Court affirmed, holding that Appellant failed to raise grounds cognizable in a habeas proceeding, and therefore, the circuit court properly dismissed the petition. View "Gardner v. Hobbs" on Justia Law

Posted in: Criminal Law
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Petitioner was convicted on three counts of aggravated robbery and one count of theft of property. Petitioner was sentenced to an aggregate term of three consecutive life sentences plus 360 months’ imprisonment. Here, Petitioner filed a pro se petition and an amended petition seeking to reinvest jurisdiction in the trial court to proceed with a petition for writ of error coram nobis, alleging that the judge in his case was biased and that the prosecutor engaged in impermissible misconduct. The Supreme Court denied the petitions, holding (1) Petitioner did not make the necessary showing of fundamental error to support relief where there was no demonstration of actual bias; and (2) Petitioner’s allegations of prosecutorial misconduct were either conclusory or were not the type that provide grounds for the writ. View "Chatmon v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of rape, residential burglary, and third-degree domestic battery. Appellant later filed this petition for writ of habeas corpus challenging the judgment reflecting his criminal convictions, alleging that the trial court lacked jurisdiction to convict him because he was illegally arrested, that the information charging him was defective, and that no plea was entered before his trial. The circuit court dismissed the petition. The Supreme Court affirmed the circuit court’s order dismissing the petition for the writ, holding that, although Appellant may have raised issues on appeal that questioned the jurisdiction of the trial court, none of his allegations had merit, and the circuit court did not clearly err in finding that Appellant’s petition did not set forth the required probable cause. View "Anderson v. Kelley" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was convicted of first-degree murder. Appellant was sentenced to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The trial court denied relief without holding an evidentiary hearing. The Supreme Court affirmed the trial court’s order, holding that, based on a totality of the evidence under the standard set forth in Strickland v. Washington, the circuit court did not clearly err in finding that counsel’s performance was not ineffective. View "Airsman v. State" on Justia Law