Justia Arkansas Supreme Court Opinion Summaries

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

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