Justia Arkansas Supreme Court Opinion Summaries

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

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