Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law