Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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