Justia Arkansas Supreme Court Opinion Summaries

Defendant was convicted of three counts of capital murder and sentenced to life imprisonment without parole. Defendant sought habeas-corpus relief, alleging that he was being unlawfully detained because he was a juvenile at the time he committed the homicides and that he received a mandatory sentence of life imprisonment without parole in contrary to the holding in Miller v. Alabama. The circuit court vacated Defendant’s sentence of life imprisonment and remanded for resentencing, concluding that Miller applied retroactively and that habeas corpus was the proper procedural remedy. The Supreme Court reversed, holding that the court erred because it issued its order granting habeas relief without first making a finding of probable cause or otherwise following the statutory procedures for granting habeas-corpus relief. Remanded. View "Hobbs v. Hodge" on Justia Law

Defendant entered a negotiated plea of guilty to the offense of capital murder. Defendant later filed a petition for writ of habeas corpus, alleging that he was being unlawfully detained because he was a juvenile at the time of the offense and received a mandatory sentence of life without parole contrary to the holding in Miller v. Alabama. The circuit court granted habeas-corpus relief. the State appealed, arguing that the circuit court failed to follow the mandatory statutory procedures for granting habeas-corpus relief. This issue was raised in the companion case of Hobbs v. Hodge, where the Supreme Court found merit in the State’s argument and remanded for further proceedings. Because Hodge was controlling of the issue in this case, the Court adopted and incorporated by reference the reasoning set forth in Hodge and reversed and remanded for further proceedings. View "Hobbs v. Grubbs" on Justia Law

After a jury trial in 2012, Defendant was convicted of three counts of rape and one count of attempted rape of a minor. Defendant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition was denied. In 2015, Petitioner filed a petition seeking leave to proceed in the trial court with a petition for writ of error coram nobis, asserting (1) Arkansas’s postconviction remedy does not afford indigent defendants a meaningful review of ineffective assistance of counsel claims pertaining to appellate counsel, (2) he was denied effective assistance of counsel at trial, (3) his illegally obtained confession was utilized at his trial to gain the conviction against him, and (4) the prosecution withheld exculpatory evidence in his case. The Supreme Court denied the writ, holding that Defendant’s claims were either outside the scope of a coram-nobis proceeding or were conclusory. View "Dodge v. State" on Justia Law

Defendant was convicted on multiple counts of theft of property for stealing horses and equipment from a university. Defendant’s conviction was affirmed on appeal. Defendant subsequently filed a pro se petition for relief under Ark. R. Crim. P. 37, alleging multiple grounds for relief. The circuit court denied the petition without a hearing. Now represented by counsel, Defendant appealed from the circuit court’s order and made a new argument on appeal that was never presented to the circuit court. The Supreme Court affirmed without reaching the merits argued in Defendant’s appeal on the grounds that Defendant never presented her argument to the circuit court. View "Cox v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction, filed a petition for writ of habeas corpus seeking relief from a judgment convicting him of rape. In his petition, Appellant alleged that his confession was coerced, that he did not understand the plea he entered, and that his attorney was ineffective. The circuit court denied the petition, concluding that the claims raised in the petition were not cognizable in habeas proceedings. The Supreme Court affirmed, holding that Petitioner failed to meet his burden of demonstrating a basis for the writ to issue. View "Bakkala v. Hobbs" on Justia Law

Petitioner filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1. The circuit court denied the petition for lack of jurisdiction. The Supreme Court reversed and remanded because the order did not provide a basis for the circuit court’s finding that it did not have jurisdiction to consider the merits of the petition. Petitioner then filed this pro se petition for writ of mandamus in the Supreme Court requesting an order directing Circuit Judge Sam Pope to rule on the Rule 37.1 petition. Judge Pope filed a response stating that the Rule 37.1 petition was under consideration and that he had not failed to perform his duty to provide a ruling on the petition. The Supreme Court denied the petition, holding that Judge Pope stated good cause for the delay, but urged the court to promptly attend to the matter. View "Russell v. Pope" on Justia Law

After a jury trial, Appellant was found guilty of rape and sexual abuse. Appellant was sentenced to an aggregate term of life imprisonment. The Supreme Court affirmed. More than nineteen years after he was convicted, Appellant filed a pro se “Motion of Facts” alleging numerous claims of error. The trial court denied the motion. Appellant lodged an appeal but did not file a brief-in-chief. Appellant subsequently filed a “Motion on Appeal” raising the issues raised in the trial court and adding some issues not raised below. The Supreme Court dismissed Appellant’s appeal, as Appellant failed to file a brief and took no action to pursue the appeal, and declared the motion moot. View "Mills v. State" on Justia Law

Appellant was convicted of rape and sentenced to life imprisonment. Thereafter, Appellant, by and through his attorney, filed a motion for rule on clerk seeking to appeal the sentencing order. Appellant failed to file a timely notice of appeal. Appellant’s attorney admitted that the notice of appeal was untimely filed due to his error. The Supreme Court treated the motion for rule on clerk as a motion for belated appeal and granted the motion, as Appellant’s attorney candidly admitted fault for the appeal not being timely perfected in accordance with McDonald v. State. View "McClinton v. State" on Justia Law

Appellant was convicted of theft of property and sentenced to eight years imprisonment. Appellant, by and through her attorney, subsequently filed a motion for rule on clerk seeking to appeal the sentencing order. Appellant’s attorney admitted that the notice of appeal was untimely filed due to his error. The Supreme Court treated the motion for rule on clerk as a motion for belated appeal and granted the motion, as Appellant’s attorney candidly admitted fault in accordance with McDonald v. State for the appeal not being timely perfected. In addition, a copy of this opinion will be forwarded to the Committee on Professional Conduct. View "Johnson v. State" on Justia Law

Petitioner was convicted of four counts of capital murder and one count of kidnapping. Petitioner subsequently filed a timely pro se petition for postconviction relief under Ark. R. Crim. P. 37.1. The trial court denied relief. There was no timely notice of appeal as to either order. Petitioner filed this pro se motion for rule on clerk seeking to lodge the record and proceed with the appeal. The Supreme Court treated the motion as a petition for belated appeal and denied it, as Petitioner did not establish good cause to excuse the failure to file a timely notice of appeal. View "Green v. State" on Justia Law