Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of capital murder, attempted capital murder, and two counts of aggravated robbery. Appellant was sentenced to a total term of life imprisonment without parole plus ten years. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the circuit court did not err in limiting Appellant’s cross-examination of a victim concerning the victim’s potential civil lawsuit against him; (2) Appellant’s argument that the circuit court erred in prohibiting him from cross-examining the victim concerning her medical records was not preserved for review; and (3) even if the circuit court erred in allowing the State to introduce statements against Appellant under the dying-declaration exception to the hearsay rule, any error would have been harmless. View "Edison v. State" on Justia Law

In April 2015, nine prisoners (collectively, Respondents) filed an action challenging the constitutionality of Act 1096 of 2015, which set out the mandated state method of executing condemned prisoners. Thereafter, eight of the prisoners had their dates of execution set, with the first executions scheduled for October 21, 2015. On September 30, 2015, Respondents filed an emergency motion for preliminary injunction. On October 9, 2015, the circuit court issued a temporary restraining order expressly staying the executions pending a preliminary injunction hearing. The court then set the preliminary injunction hearing for March 1 and 2, 2016. Petitioners, the Director of the Arkansas Department of Correction and the Arkansas Department of Correction, petitioned the Supreme Court for a writ of certiorari lifting the stay of executions. The Supreme Court granted the petition for writ of certiorari, issued the writ, and lifted the stay of the executions entered by the circuit court, holding that the circuit court acted in excess of its jurisdiction in staying the executions. Further, the Court issued a stay of the executions pending the resolution of the litigation currently pending in the circuit court, holding that the action in the circuit court was a competent judicial proceeding. View "Kelley v. Griffen" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery and kidnapping. Petitioner was sentenced to an aggregate term of 360 months’ imprisonment. 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 which Petitioner alleged that the prosecution in his case violated Brady v. Maryland. The Supreme Court denied the petition on the ground that Petitioner did not meet his burden of exercising due diligence in making the application for coram-nobis relief or presenting a valid excuse for his delay. View "Williamson v. State" on Justia Law

After a jury trial, Petitioner was found guilty of murder in the first degree. Petitioner was sentenced to life imprisonment. The Supreme Court affirmed. Petitioner later filed in the Supreme Court a 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 because it did not establish a ground for the writ. Now before the Court was Petitioner’s second pro se coram-nobis petition, in which Petitioner alleged that the prosecution in his case violated Brady v. Maryland and that the State used “false testimony” to obtain the conviction. The Supreme Court denied the petition, holding that Petitioner failed to state a ground for the writ. View "Swanigan v. State" on Justia Law

After a second trial, Defendant was found guilty of first-degree murder, second-degree battery, and aggravated assault. The court of appeals affirmed the convictions and sentences. Defendant subsequently filed a timely petition for postconviction relief claiming that he had received ineffective assistance of counsel because counsel had failed to request various jury instructions and because counsel was ineffective with respect to his handling of evidentiary issues. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Defendant’s claims of ineffective assistance of counsel and in denying Defendant’s petition without a hearing. View "Sims v. State" on Justia Law

After a jury trial in 1983, Appellant was found guilty of three counts of rape and three counts of burglary. In 2014, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, alleging (1) his identity as the perpetrator of the rape was in question and no DNA evidence was introduced at trial, and (2) his signed confessions were not signed by him or, even if they were, they were signed under “undue duress.” The trial court denied the petition, finding that Appellant failed to rebut the presumption against timeliness and failed establish that the requested testing would produce new evidence that would support the theory of defense presented at trial. The Supreme Court affirmed, holding that where Appellant failed to state any basis to rebut the presumption against timeliness, the trial court’s denial of Appellant’s petition was not clearly erroneous. View "Sawyer v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder. Appellant was sentenced to life imprisonment without the possibility of parole. Appellant appealed, arguing for his sole point on appeal that the circuit court abused its discretion by admitting into evidence a photograph of the victim at the crime scene. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in admitting the photograph, as the photograph corroborated a police officer’s testimony about the victim’s state and enabled the jurors to better understand his testimony about the crime scene. View "Green v. State" on Justia Law

After a jury trial in 2005, Petitioner was found guilty of aggravated robbery. Petitioner was sentenced to 240 months’ imprisonment. The court of appeals affirmed. In 2014, Petitioner filed in the Supreme Court a pro se petition requesting that jurisdiction be reinvested in the trial court so that he could proceed with a petition for writ of error coram nobis. The Court denied the writ. Petitioner subsequently filed a pro se petition in the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram vobis. The Supreme Court treated the petition for a writ of coram vobis as Petitioner’s second coram-nobis petition and denied the petition, holding that Petitioner’s claims either should have been addressed in the trial court or were not cognizable in a coram-nobis proceeding. View "Chestang v. State" on Justia Law

Appellant was convicted of two counts of first-degree murder and sentenced to two consecutive life sentences. The Supreme Court affirmed in 1997. In 2010, Appellant filed in the trial court a petition for recall and for resentencing seeking resentencing based on the decision of the United States Supreme Court in Graham v. Florida. The trial court denied the petition, and the Supreme Court affirmed. In 2015, Appellant filed a pro se petition to correct sentence pursuant to Ark. Code Ann. 16-90-111, once again contending that the sentence imposed on him was illegal. The trial court denied the petition. The Supreme Court affirmed, holding that the petition did not state a basis for relief under the statute because he did not demonstrate in the petition that the sentence imposed on him was illegal. View "Bell v. State" on Justia Law

Appellant pled guilty to four counts of aggravated robbery and theft of property and was sentenced to an aggregate term of 480 months’ imprisonment. Appellant later filed an untimely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which the trial court dismissed as untimely. Appellant did not appeal that order. Thereafter, Appellant filed an untimely motion to withdraw guilty plea and set aside judgment. The trial court treated the petition as a petition for postconviction relief pursuant to Rule 37.1 and denied relief. The Supreme Court dismissed Appellant’s appeal, holding that Appellant’s unauthorized second petition was untimely, and therefore, the trial court had no jurisdiction to grant the relief sought. View "Banks v. State" on Justia Law