Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of aggravated robbery, residential burglary, and third-degree battery and was sentenced to an aggregate term of 540 months’ imprisonment. The court of appeals affirmed. Appellant filed a timely petition under Ark. R. Crim. P. 37.1 raising claims alleging ineffective assistance of both trial and appellate counsel. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant’s argument that the circuit court erred in failing to appoint counsel to represent him in the Rule 37.1 proceedings was not preserved for appeal; (2) the circuit court did not err in disposing of Appellant’s petition using an analysis of Appellant’s claims that was not proposed by the State in its response; and (3) the circuit court did not err in denying the petition without a hearing. View "Bowerman v. State" on Justia Law

In 2012, Petitioner was convicted of two counts of rape and one count of sexual indecency with a minor. The Supreme Court affirmed. Petitioner filed a pro se petition and supplemental petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging, among other claims, that he was denied effective assistance of counsel at trial, that the state postconviction remedy is not adequate to raise claims of ineffective assistance of counsel, and that the State withheld material evidence from the defense. The Supreme Court denied the petition and supplement to petition, holding (1) Petitioner’s claim under Brady v. Maryland failed; and (2) the remainder of Petitioner’s claims did not fit within the purview of a coram-nobis proceeding. View "Pruitt v. State" on Justia Law

After a bench trial, Petitioner was convicted of drug charges. After the conviction was affirmed on appeal, Petitioner filed a petition for postconviction relief under Ark. R. Crim. P. 37.1. The trial court dismissed the petition. Appellant appealed and tendered the record to the Supreme Court. The court clerk, however, declined to lodge the record because the notice of appeal was not timely filed. Thereafter, Petitioner filed a motion for rule on clerk contending that the notice of appeal was, in fact, timely. The Supreme Court dismissed the appeal, holding that the petition was not timely filed, and therefore, the record did not demonstrate that the trial court had jurisdiction to grant relief on the petition. View "Moody v. State" on Justia Law

After a jury trial, Appellant was found guilty of commercial burglary and criminal mischief in the first degree. Appellant subsequently filed a timely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting that his defense counsel provided ineffective assistance. The circuit court denied the Rule 37.1 petition without holding an evidentiary hearing. Appellant filed a notice of appeal and filed a motion seeking leave to introduce case law. The Supreme Court denied the motion and affirmed the circuit court’s order, holding that the circuit court (1) did not err in dismissing the petition without an evidentiary hearing; and (2) did not err in finding that counsel rendered effective assistance during trial. View "McLaughlin v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Defendant’s motions for directed verdict because the State presented sufficient evidence that Defendant purposely caused the victim’s death and because Defendant failed to prove the affirmative defense of mental disease or defense by a preponderance of the evidence; and (2) Defendant’s argument that the State’s comments during closing argument violated her constitutional right to a fair trial was not properly preserved for appeal. View "Fink v. State" on Justia Law

Appellant was convicted of first-degree murder and sentenced to 480 months’ imprisonment. The Court of Appeals reversed the original judgment. Petitioner was subsequently convicted of murder in the first degree and sentenced to life imprisonment. More than a decade later, Appellant second a second petition to reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of error coram nobis, alleging that he had been subjected to double jeopardy on the ground that he served three years’ imprisonment on his original conviction before he began serving his life sentence on the subsequent judgment. Appellant also filed three amendments to the petition in which he reiterated the grounds raised in the petition. The Supreme Court denied the petition and amended petitions, as a mere double-jeopardy claim is not a ground for the writ. View "Anderson v. State" on Justia Law

Appellant entered guilty pleas to aggravated robbery, theft of property, and residential burglary. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging that he received ineffective assistance of counsel. The trial court denied and dismissed the Rule 37.1 petition without a hearing. Appellant lodged an appeal of the order and filed a motion to file a belated reply brief. The Supreme Court denied the motion and affirmed the trial court’s order, holding (1) Appellant failed to demonstrate good cause for filing the reply brief outside the required time; and (2) Appellant failed to demonstrate that he was entitled to Rule 37.1 relief. View "Adkins v. State" on Justia Law

In 1993, Appellant was convicted of five counts of rape, but his convictions were reversed and remanded. In 1995, Appellant entered guilty pleas to two counts of first-degree sexual abuse and three counts of first-degree carnal abuse. In 2013, Appellant filed an amended petition for a writ of error coram nobis, arguing that he was entitled to the writ because his own military records were not disclosed to him before his 1993 trial to support his alibi defense and that his 1995 guilty pleas were coerced. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal because he had served his sentence, and therefore, and his petition was moot. View "Clay v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and abuse of a corpse. Defendant was sentenced as a habitual offender to life imprisonment on the murder charge. Defendant appealed, arguing that the circuit court erred in denying his motions for a directed verdict on both charges. The State responded that substantial evidence supported both of Defendant’s convictions. The Supreme Court affirmed, holding (1) the jury reasonably could have concluded that Defendant had a purposeful intent to kill the victim; and (2) there was sufficient proof from which the jury could have concluded that Defendant’s actions constituted abuse of a corpse. View "Williams v. State" on Justia Law

Appellant was convicted of the rape of an eleven-year-old girl and sentenced to life imprisonment. Thereafter, Appellant retained counsel, and counsel filed a verified petition pursuant to Ark. R. Crim. P. 37.1, arguing that he did not receive effective assistance of counsel at trial. The trial court denied the petition after a hearing. After the record on appeal was lodged, counsel asked to be relieved, and Appellant moved for new counsel to be appointed to represent him. The Supreme Court granted counsel’s motion to be relieved and denied Appellant’s motion for appointment of another attorney. Appellant subsequently filed a number of pro se motions. The Supreme Court granted in part and denied in part Appellant’s motions for extension of brief time and denied all other motions, as the trial court did not rule on the postconviction issues contained in the motions, the claims contained in the motions were not raised in the Rule 37.1 petition, or the motions were without merit or without a factual basis. View "Ward v. State" on Justia Law