Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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

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

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

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