Justia Arkansas Supreme Court Opinion Summaries

Appellant entered negotiated guilty pleas to kidnapping, first-degree battery, and other charges. Appellant was sentenced to 336 months’ imprisonment with ten years suspended. Appellant later filed a petition for writ of error coram nobis, alleging that the plea was coerced, that he was insane at the time the plea was entered, and that the prosecution had withheld evidence of the death of a witness and medical records. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in finding that Appellant had not demonstrated a basis for the writ for each of the three grounds in the petition. View "Culbertson v. State" on Justia Law

Appellant pled nolo contendere to third-degree domestic battery and was ordered to complete one year of probation pursuant to Act 346 of 1975. Appellant appealed to the circuit court from the order of probation. The State moved to dismiss the appeal, alleging that a defendant who enters a plea of nolo contendere and is sentenced to probation pursuant to Act 346 of 1975 is not eligible to appeal the order of probation to circuit court. The circuit court dismissed the appeal on the basis that there was no conviction from which Appellant could appeal. The Supreme Court affirmed, holding (1) the State’s reliance on Lynn v. State did not provide a basis for reversal; (2) Ark. Code Ann. 5-4-305 does not apply in this case and does not grant Appellant the right to appeal to circuit court from the district court’s order of probation; and (3) Appellant’s right to a trial by jury was not violated by the circuit court’s dismissal of his appeal from district court. View "Barner v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree battery and sentenced to 360 months’ imprisonment. The Court of Appeals affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel, insufficient evidence, and trial error. The trial court denied the petition. Appellant appealed and filed several motions seeking an extension of time to file his brief, access to the transcript, and appointment of counsel and to supplement his brief. The Supreme Court dismissed the appeal and declared the motions moot, holding that none of Appellant’s claims in the petition had merit. View "Wheeler v. State" on Justia Law

After a jury trial, Petitioner was found guilty of rape and sentenced to 300 months’ imprisonment. The Supreme Court affirmed. Now before the Court was Petitioner’s pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis. In his petition, Petitioner claimed that the State coerced the victim to testify falsely at Petitioner’s trial and that the victim later recanted her testimony. The Supreme Court denied the petition, as a writ of error coram nobis will not lie for recanted testimony, and therefore, Petitioner failed to state a claim cognizable in a coram-nobis proceeding. View "Riley v. State" on Justia Law

After a bench trial, the circuit court found Appellant guilty of driving while intoxicated, second offense, and of violating the implied-consent law. Appellant appealed, arguing that the circuit court erred in denying his motion to suppress the results of a blood-alcohol test taken pursuant to a search warrant. Specifically, Appellant contended that the implied-consent statutes prohibit the issuance of a warrant to obtain a chemical test. The Supreme Court affirmed Defendant’s conviction and sentence, holding that the laws of Arkansas do not prohibit an officer from obtaining a warrant once an accused declines the test requested by the officer under the implied-consent law. View "Metzner v. State" on Justia Law

After a jury trial, Appellant and a co-defendant were found guilty of capital murder. The Supreme Court reversed and remanded for separate trials. The co-defendant subsequently pleaded guilty to second-degree murder and testified for the prosecution at Appellant’s retrial. After his trial, Appellant was found guilty of first-degree murder. The Supreme Court affirmed. Appellant later filed a pro se petition to proceed in forma pauperis, arguing that, when the co-defendant entered his guilty plea he admitted to killing the victim and that the admission constituted exculpatory evidence withheld by the state. Appellant also sought the transcripts of the proceeding in which the co-defendant entered his guilty plea. The trial court denied both requests. The Supreme Court affirmed, holding that Appellant did not offer any factual support for the claim that the State withheld the information concerning the plea from the defense at the time of trial and that Appellant failed to show that the transcripts should be provided to him at no cost. View "McDaniel v. State" on Justia Law

Appellant entered a pea of guilty to two counts of rape and was sentenced to serve an aggregate term of 360 months’ imprisonment. Appellant subsequently filed in the trial court a pro se petition for writ of error coram nobis, arguing that he was incompetent when the plea was entered and that a competency hearing should have been held before the plea was entered. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in denying the coram-nobis petition because Appellant failed to assert facts in support of the allegations contained in the petition that established a ground for the writ. View "Markus v. State" on Justia Law

After a jury trial, Petitioner was convicted of capital murder, residential burglary, attempted capital murder, rape, and aggravated robbery. Petitioner was sentenced to death for the capital murder conviction. The Supreme Court affirmed Petitioner’s convictions and sentences. Petitioner sought postconviction relief under Ark. R. Crim. P. 37.1, and the Supreme Court affirmed the circuit court’s denial of the petition. Petitioner now petitioned the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, arguing that the prosecution withheld material evidence in violation of Brady v. Maryland. The Supreme Court granted the petition to reinvest jurisdiction, holding that the State withheld evidence that might have led counsel to utilize a defense based on an alternate suspect. View "Isom v. State" on Justia Law

After a jury trial in 2001, Petitioner was convicted of capital murder, residential burglary, attempted capital murder, rape, and aggravated robbery. Petitioner was sentenced to death for the capital murder conviction. The Supreme Court affirmed Petitioner’s convictions and sentences. In 2005, Petitioner filed a second petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging eleven claims for relief. The trial court dismissed the petition, and the Supreme Court affirmed. Petitioner then filed the instant motion seeking recall of the Court’s mandate in his Rule 37 case, alleging, among other claims, that he was denied effective, conflict-free representation. The Supreme Court denied the petition, holding (1) Petitioner failed to identify any error on the part of the Court that would constitute a breakdown in the appellate process; and (2) Petitioner’s claim that he was categorically ineligible for the death penalty was not yet ripe because there was no date set for Petitioner’s execution. View "Isom v. State" on Justia Law

After a jury trial, Petitioner was found guilty of four counts of aggravated robbery, three counts of misdemeanor theft of property, and one count of felony theft of property. Petitioner was sentenced as a habitual offender to an aggregate term of 2880 months’ imprisonment. Now before the Court was Petitioner’s second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, in which Petitioner alleged that the prosecution concealed evidence from the defense. The Supreme Court denied the writ, holding that there was no Brady violation and that the remainder of Petitioner’s allegations were not cognizable in a coram-nobis proceeding. View "Hutcherson v. State" on Justia Law