Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a conditional plea of no contest to one count of misdemeanor possession of a firearm by certain persons. Appellant appealed, arguing that the circuit court erred in denying his motion to dismiss because (1) he had not been adjudicated mentally ill or involuntarily committed to a mental institution in violation of Ark. Code Ann. 5-73-103(a), and (2) section 5-73-103(a)(3) is void for vagueness, violates Appellant's due process under the federal Constitution, and violates the Second Amendment to the federal Constitution and article 2, section 5 of the state Constitution. The Supreme Court dismissed in part and affirmed in part, as (1) Appellant’s first point was not properly before the Court; and (2) Appellant’s remaining points were not raised below and ruled upon by the circuit court. View "Gooch v. State" on Justia Law

After a jury trial, Petitioner was found guilty of capital murder and sentenced to death. The Supreme Court affirmed. In 2010, Petitioner filed a pro se petition asking that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, claiming, among other things, that the State withheld exculpatory evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, concluding that Petitioner did not establish a Brady violation. 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 again claimed that there was other evidence hidden by the State at trial in violation of Brady. The Supreme Court denied the petition, holding (1) Petitioner failed to establish a Brady violation; and (2) the remainder of Petitioner’s claims were not within the purview of a coram-nobis proceeding. View "Fudge v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of capital murder and two counts of firearm enhancements. Appellant was sentenced to two terms of life imprisonment without the possibility of parole for the capital murders. The Supreme Court affirmed the convictions and sentences, holding (1) substantial evidence supported Appellant’s convictions and sentences; (2) the circuit court did not abuse its discretion when it denied Appellant’s motion to dismiss based on prosecutorial delay; (3) the circuit court did not err in granting the State’s motion in limine to prevent Appellant from introducing evidence that third persons may have committed the murders; and (4) the circuit court did not err its rulings on five evidentiary issues regarding relevancy. View "Conte v. State" on Justia Law

Petitioner was convicted of second-degree murder and aggravated residential burglary and sentenced to an aggregate sentence of 720 months’ imprisonment. Petitioner filed a timely amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court dismissed the petition. Petitioner then filed a motion requesting modification of the order of dismissal, contending that the trial court had overlooked issues presented in the amended petition. The trial court denied the motion. Petitioner subsequently filed in the Supreme Court a motion requesting permission to proceed with a belated appeal of the dismissal of his Rule 37.1 petition, contending that he did not receive a copy of the order denying the motion until the extended time for filing a notice of appeal had expired. The Supreme Court granted the motion, holding that Petitioner stated good cause for the procedural default. View "Berks v. State" on Justia Law

Defendant was charged with sexual assault in the fourth degree. Defendant moved to suppress a statement that he had given, asserting that, prior to being interviewed, he had not been advised of his Miranda rights. The circuit court granted Defendant’s motion to suppress, concluding that the protections of Miranda applied to the circumstances surrounding Defendant’s interview by law enforcement. The Supreme Court dismissed the appeal, holding that the necessary inquiry in this case involves a mixed question of law and fact and is an appeal not requiring the interpretation of the Court’s criminal rules with widespread ramifications. View "State v. Payton" on Justia Law

Defendant was driving her car when she collided with Plaintiff, a pedestrian, in a crosswalk. Plaintiff sued Defendant for negligence. The jury returned a verdict in Plaintiff’s favor. Defendant filed a motion for a new trial under Ark. R. Civ. P. 59(a)(2), arguing that Plaintiff’s counsel had misrepresented certain facts to the jury during closing argument. The circuit court agreed with Defendant and granted a new trial. The Supreme Court affirmed, holding (1) Defendant did not waive her right to a new trial for defense counsel’s failure to object during closing argument; and (2) the circuit court did not abuse its discretion in granting a new trial. View "Smith v. Hopper" on Justia Law

Appellant was convicted of three counts of second-degree sexual assault. The conviction was affirmed on appeal. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, raising claims of ineffective assistance of trial counsel and claims of independent constitutional error. The trial court denied postconviction relief. The Supreme Court affirmed, holding (1) Petitioner failed to make required showings under the Strickland analysis that his trial counsel provided ineffective assistance; (2) Appellant failed to demonstrate that appellate counsel was ineffective; and (3) Appellant failed to establish with factual substantiation that his claims of prosecutorial misconduct or due process violations were sufficient to void the judgment in his case, and the trial court’s findings were not clearly erroneous. View "Savage v. State" on Justia Law

After a jury trial, Petitioner was found guilty of residential burglary and rape and sentenced to an aggregate sentence of 900 months’ imprisonment. The court of appeals affirmed. Petitioner later filed in the Supreme Court a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the State had withheld evidence favorable to the defense. The Supreme Court denied the petition. Petitioner subsequently filed a second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was incompetent at the time of trial because of mental problems, that the trial court made errors at trial, that the prosecution withheld evidence from the defense, and that his trial counsel provided ineffective assistance. The Supreme Court again denied relief, holding (1) Petitioner failed to demonstrate incompetence at the time of trial; (2) claims of trial error do not warrant coram-nobis relief; (3) Petitioner failed to establish a Brady violation; and (4) allegations of ineffective assistance of counsel are not a ground for relief on a petition for writ of error coram nobis. View "Noble v. State" on Justia Law

Petitioner filed a petition for writ of mandamus in the Supreme Court pertaining to a pro se petition for writ of habeas corpus he filed in the circuit court. Petitioner argued that his petition for writ of habeas corpus was meritorious and that the Supreme Court should release him from custody on the grounds raised in the habeas petition. The circuit court acted on the habeas petition approximately two months before this mandamus action was filed, and a copy of the order was provided to Petitioner. The Supreme Court dismissed Petitioner’s petition for writ of mandamus, holding that a writ of mandamus will not issue where Petitioner had the adequate remedy of seeking review by appeal. View "McClinton v. State" on Justia Law

After a jury trial, Appellant was found guilty of kidnapping and rape. Appellant was sentenced to life imprisonment for rape. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The circuit court denied relief, and the Supreme Court affirmed. Thereafter, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 seeking scientific testing of items he alleged were found at the crime scene. The circuit court denied the petition, concluding that Appellant failed to present any new scientific evidence. The Supreme Court affirmed, holding that Appellant failed to demonstrate any error in the circuit court’s denial of his Act 1780 petition. View "Lewis v. State" on Justia Law