Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of possession of drug paraphernalia with intent to manufacture methamphetamine and possession of drug paraphernalia. Appellant was sentenced to a total of 144 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37, alleging ineffective assistance of counsel. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) trial counsel erred by failing to object to the prosecutor’s statement that the jury had not “heard both sides yet” but, even assuming that the statement was improper, Appellant failed to show that she was prejudiced by the statement; and (2) the Court declined to overrule previous decisions refusing to apply the cumulative-error doctrine to claims of ineffective assistance of counsel. View "Houghton v. State" on Justia Law

Defendant was charged with the first-degree murder of John Davis. The jury found Defendant guilty of the lesser-included offense of second-degree murder. The court of appeals affurned, concluding that substantial evidence supported the jury’s finding that Defendant acted with the purpose to seriously injure Davis. Defendant subsequently filed a verified, pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant received effective assistance of counsel; and (2) Defendant’s remaining arguments were not cognizable under Rule 37.1. View "Hooks v. State" on Justia Law

Appellant filed a petition for judicial review of an administrative decision pursuant to Ark. Code Ann. 25-15-212 of the Administrative Procedure Act (APA) seeking review of a disciplinary action brought against him by the Arkansas Department of Correction (ADC). The circuit court affirmed the ADC’s administrative decision. Before the Supreme Court was the ADC’s motion to dismiss Appellant’s appeal and Appellant’s pro se motion for extension of time to file his brief-in-chief. The Supreme Court granted the motion to dismiss and declared Appellant’s motion for extension of time moot, holding that because Appellant failed to timely file his petition in accordance with the time limitations of the APA, he was precluded from seeking relief under the statute. View "Day v. Minor" on Justia Law

Petitioner filed a pro se petition for writ of habeas corpus. The circuit court denied the petition, and no timely appeal was taken. Petitioner in the instant motion sought leave to proceed with a belated appeal, alleging that he belatedly received notice of the order of denial and that, due to disciplinary actions and grievances filed with the Arkansas Department of Corrections, he was unable to obtain the proper forms to file a timely notice of 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 "Barber v. State" on Justia Law

The State charged Defendant with one count of arson. Defendant filed a motion to suppress evidence seized in a warrantless search of Defendant's burned building that was conducted three days after the fire during an insurance company investigation. Defendant asserted that law enforcement officers did not have probable cause to search the building without a search warrant, and therefore, the search was invalid. The circuit court granted Defendant’s motion to suppress, finding that certain evidence and photographs taken from the burned premises during the warrantless search violated the Fourth Amendment. The State brought this interlocutory appeal. The Supreme Court dismissed the appeal, as the appeal did not involve the interpretation of the law or the uniform administration of justice, as required by Ark. R. App. P.-Crim. 3(c). View "State v. Brashers" on Justia Law

After a jury trial, Appellant was found guilty of murder in the second degree and being a felon in possession of a firearm. Appellant was sentenced as a habitual offender to a term of imprisonment and a fine. The court of appeals affirmed. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that he was denied the effective assistance of counsel in several respects. Appellant's petition was denied. The Supreme Court affirmed, holding that Appellant failed to meet his burden of establishing that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Stalnaker v. State" on Justia Law

In 2012, a judgment of conviction was entered against Appellant for two counts of capital murder committed in 1989. The Supreme Court affirmed. Seventy-eight days after the mandate had issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 challenging the judgment. The trial court dismissed the petition, concluding that it was not timely filed. Appellant appealed. The Supreme Court dismissed the appeal, holding that because the petition was not timely filed, the trial court had no jurisdiction to grant the relief sought, and as such, the appellate court also lacked jurisdiction. View "Sanders v. State" on Justia Law

After a jury trial, Appellant was convicted of raping a mentally handicapped sixteen-year-old girl. The circuit court sentenced Appellant as a habitual offender to life imprisonment. Appellant appealed, arguing that he was denied a fair trial because the circuit court refused to grant a mistrial based upon a comment made by a prospective juror during jury selection because the comment tainted the jury pool with impermissible character evidence. The Supreme Court affirmed, holding that Appellant was not entitled to a new trial where the prospective juror’s comment did not rise to the level of prejudicial error so severe that a new trial was needed and where Appellant failed to request a curative instruction. View "McClinton v. State" on Justia Law

Appellant filed a pro se motion to amend a petition for writ of habeas corpus previously filed in the circuit court challenging his conviction and sentence for four counts of rape. The amended petition alleged that the State failed to prove all elements of the offenses, that counsel did not preserve the issue of failure of proof for appeal and that the trial court lost jurisdiction because a speedy-trial violation occurred. The circuit court denied the amended petition. The Supreme Court affirmed, holding that Appellant’s claims were not cognizable grounds for the writ. View "Jones v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of capital murder. Appellant was sentenced to life in prison without parole. The Supreme Court affirmed, holding (1) Appellant’s argument that the circuit court erred in failing to instruct the jury on the lesser-included offenses of first- and second-degree murder was not preserved for appellate review; (2) the circuit court did not abuse its discretion in admitting certain autopsy photographs; and (3) Appellant was precluded from challenging the admission of a letter he wrote and attempted to send from the jail. View "Evans v. State" on Justia Law