Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of the rape of his daughter. The court of appeals affirmed. Defendant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was denied effective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant’s request for relief where Defendant failed to establish that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Henson v. State" on Justia Law

Petitioner filed a petition for writ of habeas corpus alleging that the judgment in his criminal case was invalid on its face. The circuit court denied the petition. Petitioner filed a timely notice of appeal. Petitioner, however, did not tender a record containing the habeas petition to the Supreme Court until he filed the instant motion for belated appeal. The Supreme Court treated the motion as motion for rule on clerk and denied it because Petitioner did not establish any cause to grant the writ of habeas corpus and, therefore, could not prevail on appeal. View "Early v. Hobbs" on Justia Law

After a jury trial in 1979, Petitioner was found guilty of felony murder and sentenced to life imprisonment without parole. Now before the Supreme Court was Petitioner’s second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The petition arose following a notification that Petitioner received from the U.S. Department of Justice that FBI Laboratory Examiner Michael Malone, the expert witness at Petitioner’s trial, had been identified as an examiner whose work failed to meet professional standards. The Supreme Court appointed an attorney to represent Petitioner in this proceeding, concluding that Petitioner had made the required showing that he may be entitled to postconviction relief and, given the complexity and first impression issues involved, Petitioner could not properly proceed without counsel. View "Pitts v. State" on Justia Law

Game wardens conducted an investigation into Appellant’s compliance with hunting laws. After the investigation was completed, the officers began a criminal investigation seeking information to determine whether Appellant was a felon. Upon discovering that he was a felon, the officers arrested and searched Appellant. Appellant filed a motion to suppress, arguing that he was unlawfully detained and unlawfully searched because the game wardens had neither a warrant nor a reasonable suspicion of any violation of law. The circuit court denied the motion. The Supreme Court agreed with Appellant and reversed, holding that, under the circumstances of this case, the officers did not have reasonable suspicion to conduct a criminal investigation. Remanded. View "Pickle v. State" on Justia Law

Appellant was convicted of two counts of first-degree murder for the deaths of Tracey Mills and David Smith. Appellant was sentenced to two consecutive life sentences. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in (1) refusing to instruct the jury on extreme-emotional-disturbance manslaughter as a lesser-included offense of first-degree murder; and (2) allowing the prosecutor to state in closing argument that “one of the victims did not deserve to die” during the State’s closing rebuttal argument. View "Davis v. State" on Justia Law

After a jury trial, Appellant was convicted and sentenced for one count each of first-degree murder, aggravated robbery, felony theft, and misdemeanor theft. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) Appellant failed to preserve for appeal his argument that the circuit court erred in denying his motion to suppress an out-of-court identification made pursuant to a photographic lineup because the photographic lineup was unduly suggestive; (2) the circuit court did not err in failing to conduct a hearing following an ex parte communication with a juror; but (3) the trial court erred in sentencing Appellant. View "Thompson v. State" on Justia Law

Petitioner was convicted of first-degree murder and committing a terroristic act and was sentenced to an aggregate term of 360 months’ imprisonment. Now before the Supreme Court was Petitioner’s pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis. Petitioner alleged that jurisdiction should be reinvested in the circuit court to consider a coram-nobis petition because he was not afforded postconviction counsel to assist him in raising claims of ineffective assistance of trial counsel. The Supreme Court denied the petition, holding that Petitioner failed to state a claim cognizable in a coram-nobis proceeding. View "Sims v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder. Defendant was sentenced to life without parole. Defendant appealed, arguing that the circuit court abused its discretion by declining to give his proffered, nonmodel jury instruction concerning when a juror, who has reasonable doubt about a defendant’s guilt on capital murder, may transition to the lesser-included offense of first-degree murder. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in refusing to give Defendant’s proffered modification, as the jury was properly instructed with regard to reasonable doubt. View "Nichols v. State" on Justia Law

After a jury trial in 1995, Appellee was convicted of capital murder and sentenced to a mandatory life sentence without the possibility of parole. In 2013, Appellee filed a petition for writ of habeas corpus asserting that his sentence to life imprisonment was illegal pursuant to Miller v. Alabama because he was a juvenile at the time of the offense. The circuit court granted Appellee’s petition, vacated and set aside his offense, and reinvested the circuit court that convicted Appellee with jurisdiction to conduct resentencing proceedings. The Supreme Court reversed and remanded, holding that the circuit court had not followed the procedures mandated by the habeas-corpus statutes. On remand, the circuit court held a hearing and ruled that Appellee was entitled to relief. The Supreme Court affirmed, holding (1) the circuit court did not err by concluding that Miller applies retroactively; and (2) the circuit court’s ruling regarding equal protection and due process was not in error. View "Kelley v. Gordon" on Justia Law

Defendant was convicted for the rape of his fourteen-year-old daughter and was sentenced to 240 months’ imprisonment. The Supreme Court affirmed. Defendant later filed a pro se petition seeking leave to proceed in the trial court with a petition for writ of error coram nobis, contending, inter alia, that the prosecution at his trial withheld exculpatory evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) Defendant’s claim that the State wrongfully withheld material evidence under Brady failed; and (2) Defendant’s remaining argument did demonstrate a ground for relief within the scope of a coram-nobis proceeding. View "Vance v. State" on Justia Law