Justia Arkansas Supreme Court Opinion Summaries

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

After a jury trial, Appellant was convicted of two counts of capital murder. Appellant also pled guilty to one count of possessing a controlled substance. Appellant was sentenced to life imprisonment without parole for each of the capital-murder convictions and twenty-five years’ imprisonment on the possession of a controlled substance conviction, with all sentences to run concurrently. The Supreme Court affirmed the convictions and sentences, holding that, under the circumstances of this case, the circuit court did not abuse its discretion in limiting the scope of Appellant’s recross-examination of a witness at trial. View "Patillo v. State" on Justia Law

After a jury trial, Appellant was found guilty of one count of rape, one count of incest, four counts of sexual abuse, and thirteen counts of sexual assault. The court of appeals affirmed. While incarcerated, Appellant filed a pro se petition for writ of habeas corpus, claiming that his judgment was invalid for several reasons. The circuit court dismissed the petition because Appellant failed to attach a copy of his judgment-and-commitment order and because some of his claims were not cognizable in a habeas proceeding. The Supreme Court affirmed, holding that Appellant did not establish any cause to grant the writ of habeas corpus because he failed to show that his commitment was invalid on its face or that the circuit court lacked jurisdiction. View "Grissom v. Hobbs" on Justia Law

After a jury trial, Petitioner was found guilty of rape and sentenced as a habitual offender to 300 years’ imprisonment. The Supreme Court affirmed. Thereafter, Petitioner filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1. The trial court denied the petition on the ground that it was not timely filed. Petitioner’s appeal was dismissed. 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 failed to state a ground for the writ. View "Franklin v. State" on Justia Law

After a jury trial, Appellant was found guilty of manslaughter and third-degree battery. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, claiming that he was denied effective assistance of counsel at trial. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not prejudiced by counsel’s failure to object in the guilt phase to an erroneous instruction; (2) Appellant’s second allegation of error was too vague to constitute a showing of ineffective assistance under Strickland; and (3) Appellant’s claim that the trial court erred when it failed to appoint counsel to represent him in the Rule 37.1 proceeding was not preserved for appeal. View "Detherow v. State" on Justia Law

Petitioner, an inmate, filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1. The circuit court denied the petition for lack of jurisdiction. The Supreme Court reversed and remanded on the basis that the order did not provide a basis for the circuit court’s finding and that the petition was both timely and verified. Petitioner subsequently filed a pro se petition for writ of mandamus in the Supreme Court alleging that the circuit judge had failed to provide a timely ruling on the Rule 37.1 petition. The Supreme Court denied the petition. Petitioner then filed a second mandamus petition, contending that the judge had failed to provide a timely ruling on the Rule 37.1 petition. After filing his initial response, the circuit judge filed an amended response that attached an order dismissing the Rule 37.1 petition. The Supreme Court dismissed Petitioner's petition as moot, as the order attached to the amended response disposed of the matter. View "Russell v. Pope" on Justia Law

After a jury trial, Appellant was found guilty of four counts of computer exploitation of a child in the first degree in violation of Ark. Code Ann. 5-27-605(a) and of twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child in violation of Ark. Code Ann. 5-27-602(a). On appeal, Appellant argued that the circuit court erred by not reducing each charge to a single count in violation of his right to be free from double jeopardy. The Supreme Court affirmed, holding (1) section 5-27-602 does not impose multiple prosecutions for the same offense in violation of the double jeopardy clause, as the statute authorizes separate convictions for each prohibited photograph and videotape that is possessed; and (2) with respect to his convictions under section 5-27-605, Appellant did not provide any argument explaining how his multiple convictions under the statute result in a double-jeopardy violation. View "Rea v. State" on Justia Law

Defendant pled guilty to thirty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child, first offense. Defendant effectively received a sixty-year sentence in the Arkansas Department of Correction. Defendant later filed a pro se petition for writ of error coram nobis and other relief stating that he had illegally been sentenced for thirty crimes because he had sent only one computer file. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition, as none of Defendant’s claims fell within any of the four categories of recognized claims for writ of error coram nobis. View "Pelletier v. State" on Justia Law