Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Defendant was convicted of the introduction of a controlled substance into the body of her newborn baby. The court of appeals affirmed. At issue on appeal was whether Defendant could be convicted of Ark. Rev. Stat. 5-13-210 by “otherwise introduc[ing]” methamphetamine into her baby’s system when the child was outside the womb but still attached to the placenta by the umbilical cord. The Supreme Court reversed and dismissed, holding (1) the phrase “otherwise introduced” must be interpreted to refer to an active process and not to passive bodily processes that result in a mother’s use of a drug entering her newborn child’s system; and (2) therefore, Defendant’s conviction cannot stand. View "Arms. v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Petitioner was found guilty of murder in the first degree. Petitioner was sentenced as a habitual offender to 480 months’ imprisonment. Petitioner 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 coram-nobis petition. Petitioner later filed a second 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 cause to reinvest jurisdiction in the trial court to consider his coram-nobis petition. View "Wallace v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was convicted of aggravated robbery, theft of property, first-degree battery, and committing a terroristic act in connection with a drug buy. Appellant was sentenced to a total of eighty-seven years in the Arkansas Department of Correction. The court of appeals affirmed. Appellant subsequently filed a petition under Ark. R. Crim. P. 37, alleging ineffective assistance of appellate counsel and that he was improperly convicted of both aggravated robbery and first-degree battery because the first-degree battery charge is a lesser-included offense of aggravated burglary. The State conceded that Appellant was subjected to double jeopardy on the charges of aggravated robbery and first-degree battery. The circuit court denied Appellant’s claim of ineffective assistance of counsel and dismissed the offense of battery in the first degree. The Supreme Court affirmed, holding that appellate counsel provided constitutionally effective assistance. View "Taylor v. State" on Justia Law

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In 1996, Petitioner entered a plea of guilty to multiple felony offenses. The circuit court imposed an aggregate sentence of 720 months’ imprisonment. In 2014, Petitioner filed a pro se “Petition for Declaratory Judgment That a Breach of Plea Agreement Occurred and request for Order Nunc Pro Tunc.” The circuit court denied the petition. Petitioner took no appeal. Petitioner subsequently sought leave from the Supreme Court to proceed with a belated appeal. The Supreme Court denied the motion, holding that Petitioner failed to demonstrate good cause for not conforming to the rules of procedure and that, even if the appeal were allowed to proceed, Petitioner could not prevail. View "Purifoy v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Defendant was convicted of one count of rape. The trial court sentenced Defendant to life imprisonment. Defendant’s sole point on appeal was that the trial court erred by denying his motion for a mistrial based on a statement made by the prosecutor that Defendant argued was an impermissible comment on his right not to testify at trial. The Supreme Court affirmed Defendant’s conviction, holding that that issue of whether Defendant would testify was not referenced by the prosecutor, and therefore, the trial court did not err in denying Defendant’s motion for a mistrial. View "Paulson v. State" on Justia Law

Posted in: Criminal Law
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After a jury trial, Appellant was found guilty of sexual assault in the first degree and sexual assault in the second degree. Appellant was sentenced to concurrent terms of forty and thirty years imprisonment. The Supreme Court affirmed, holding that the circuit court did not err by (1) permitting evidence of prior misconduct under the “pedophile exception” to Ark. R. Evid. 404(b); (2) not allowing, under the rape-shield statute, evidence of the victims’ motives to falsely accuse Appellant of the crimes; and (3) denying Appellant access to one of the victim’s psychological records under the psychotherapist/patient privilege. View "Holland v. State" on Justia Law

Posted in: Criminal Law
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Appellant pleaded guilty to first-degree murder. Appellant was sentenced to life imprisonment with a concurrent ten-year enhancement for committing the murder in the presence of a child. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant’s motion to suppress a portion of the booking video depicting incriminating statements made by Appellant; (2) Appellant failed to preserve his argument that the circuit court erred in limiting Appellant to evidence related to the events that occurred on the afternoon and evening of the shooting; and (3) the circuit court did not err in rejecting Appellant’s intoxication as a mitigating circumstance during sentencing. View "Griffin v. State" on Justia Law

Posted in: Criminal Law
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Defendant was convicted of capital murder and criminal attempt to commit capital murder and sentenced as a habitual offender to life imprisonment without parole and life imprisonment, respectively. Defendant appealed. Defendant’s attorney also filed a no-merit brief and a motion to withdraw. The Supreme Court affirmed the convictions and granted counsel’s motion to withdraw, holding (1) none of the rulings adverse to Defendant presented meritorious grounds for reversal; (2) Appellant’s claims that his counsel was ineffective were not preserved for appellate review; and (3) the prosecution did not commit a Brady violation during the proceedings. View "Gordon v. State" on Justia Law

Posted in: Criminal Law
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Appellant entered a plea of guilty to first-degree murder, aggravated assault, and furnishing prohibited articles. Appellant was sentenced to an aggregate term of 552 months’ imprisonment. Appellant later filed a pro se motion for production of documents alleging that the prosecuting attorney had not made available to him several documents that he desired to receive for “his discovery of his criminal case file.” The trial court denied the motion on the grounds that the discovery process had been completed in Appellant’s case and that the prosecuting attorney was not required to provide documents not included in Appellant’s files. The Supreme Court affirmed, holding that the trial court did not err in ruling that Appellant was not entitled to the discovery sought. View "Gonder v. State" on Justia Law

Posted in: Criminal Law
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Petitioner entered negotiated pleas in four separate cases to possession of a firearm by a felon, aggravated robbery, and theft of property. Petitioner also entered a plea directly to the court to a charge of residential burglary in one of the four cases. Petitioner later filed a single petition for postconviction relief under Ark. R. Crim. P. 37.1 challenging his convictions in all four cases. The trial court denied the petition. Petitioner tendered the record for appeal, but the Supreme Court clerk declined to lodge it because the notice of appeal was not timely filed. Thereafter, Petitioner filed the instant motion for belated appeal. The Supreme Court denied the motion, holding that Petitioner failed to establish good cause for his failure to file a timely notice of appeal. View "Clay v. State" on Justia Law

Posted in: Criminal Law