Justia Arkansas Supreme Court Opinion Summaries

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

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