Justia Arkansas Supreme Court Opinion Summaries

In three separate cases, Defendant pled guilty or nolo contendere to third-degree domestic battering, third-degree domestic battering (second offense), and first-degree domestic battering. Defendant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court dismissed the petition on the grounds that the petition did not meet the time limitations on filing petitions set by Ark. R. Crim. P. 37.2(c)(i). Petitioner then filed a pro se motion for belated appeal. The Supreme Court dismissed the motion, holding that the petition filed by Defendant was not filed within the ninety-day period in any of his cases. View "Joslin v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder for strangling his prison cellmate to death. Defendant was sentenced to death for the murder. Defendant appealed, raising three claims. The only issue properly preserved for appeal was whether the circuit court erred in sustaining Holland’s Batson challenge to the State’s use of peremptory strikes to exclude three African Americans from the jury. The Supreme Court affirmed the conviction and sentence of death, holding that the circuit court’s decision to reject the Batson challenge was not clearly against the preponderance of the evidence. View "Holland v. State" on Justia Law

After a jury trial in 2003, Petitioner was found guilty of capital murder and battery in the first degree. In 2015, Petitioner filed his fourth petition to reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of error coram nobis, alleging several grounds for the writ. The Supreme Court dismissed the petition, holding that Petitioner’s claims for relief were either not within the purview of the writ, were improperly raised in this coram-nobis proceeding, were without merit, or were an abuse of the writ. View "Grant v. State" on Justia Law

After a jury trial, Defendant was found guilty of two counts of rape for the sexual assault of his stepdaughter. The court of appeals affirmed. Thereafter, Defendant filed an untimely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition was denied. Defendant later filed this pro se petition and supplemental petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the State withheld evidence from the defense at trial, that he received ineffective assistance of counsel at trial, and that the state postconviction remedy is inadequate to allow a meaningful review of ineffective assistance of counsel claims. The Supreme Court denied the petition and supplemental petition, holding that Defendant’s claims were either not cognizable in error-coram-nobis proceedings or were unsupported by the facts or by convincing legal authority. View "Ball v. State" on Justia Law

After a jury trial, Defendant was found guilty of attempted capital felony murder and was sentenced as a habitual offender to life imprisonment. Now before the Supreme Court was Defendant’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In his petition, Defendant alleged that he was tried by a court without jurisdiction, that he was subjected to double jeopardy, that he was denied effective assistance of counsel, and that the evidence was insufficient to sustain the conviction. The Supreme Court denied the petition, holding that Defendant’s claims were either without merit or were not cognizable in coram-nobis proceedings. View "Goodwin v. State" on Justia Law

Appellant was convicted of two counts of first-degree sexual assault on a guilty plea. Appellant was sentenced to concurrent terms of 240 months’ imprisonment with an aggregate sentence of forty years’ imprisonment. Appellant filed a petition for writ of habeas corpus raising several claims. The circuit court denied relief, concluding that the petition did not establish probable cause that Appellant was being held illegally, that the trial court lacked jurisdiction, or that the commitment was invalid on its face. The Supreme Court affirmed, holding that the claims stated in Appellant’s petition did not state a basis to support issuance of the writ. View "Woodson v. Hobbs" on Justia Law

After a bench trial, Appellant was found guilty of rape and sentenced as a habitual offender to 600 months’ imprisonment. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging ineffective assistance of counsel. The trial court dismissed the petition, and the Supreme Court dismissed Appellant’s appeal. Appellant subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case, contending that he had not been afforded an adequate opportunity to present claims of ineffective assistance of counsel. The Supreme Court denied the petition, holding that Petitioner’s claim was not within the scope of a coram-nobis proceeding. View "Stevenson v. State" on Justia Law

In 2013, Appellant entered guilty pleas to multiple felony offenses. In 2014, Appellant filed a petition seeking a writ of habeas corpus, making numerous allegations. The circuit court dismissed the petition. Before the time for filing a notice of appeal had elapsed, Appellant filed a motion asking that the order be modified and vacated. The motion was denied. Appellant appealed from both orders. The Supreme Court dismissed the appeal and declared moot the motions Appellant filed for copies and for extension of time, holding that Appellant did not establish any cause to grant a writ of habeas corpus, and therefore, there was no merit to his appeal. View "Smith v. Hobbs" on Justia Law

In 2002, after a jury trial, Petitioner was found guilty of the rape of a child less than fourteen years of age and two counts of sexual assault in the first degree. In 2014, Petitioner filed a pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, asserting that material evidence was withheld from him in violation of Brady v. Maryland. The Supreme Court denied relief. In 2015, Petitioner filed a second pro se petition to reinvest jurisdiction to proceed with a coram-nobis petition, asserting that he obtained new evidence of a Brady violation. The Supreme Court denied the petition on the ground that Petitioner failed to bring all allegations in his first coram-nobis petition, Petitioner failed to exercise diligence in bringing his claim regarding the evidence at issue, and the evidence would not have been sufficient to undermine confidence in the verdict. View "Ratchford v. State" on Justia Law

Appellant, an inmate, filed a petition for writ of habeas corpus, asserting that the trial court lost jurisdiction when Appellant’s attorney admitted to what Appellant characterized as a conflict of interest and that his sentence was illegal because the trial court did not appropriately inquire into the alleged conflict. The circuit court denied habeas relief. Appellant appealed and also filed a motion in which he sought to amend his habeas petition. The Supreme Court affirmed the circuit court’s order finding that the petition was without merit, and therefore, the motion was moot. View "Maier v. State" on Justia Law