Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
by
After a jury trial, Petitioner was convicted of capital murder and was sentenced to life imprisonment without parole. The Supreme Court affirmed. Now before the Supreme Court was Petitioner’s second pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis. In the petition, Petitioner asserted that the prosecutor withheld exculpatory evidence and knowingly allowed the State’s witnesses to commit perjury. The Supreme Court denied the petition on the grounds that Petitioner failed to meet his burden of establishing a fundamental error of fact extrinsic to the record sufficient to overcome the presumption that the judgment of conviction in his case was valid. View "Barnett v. State" on Justia Law

Posted in: Criminal Law
by
After a jury trial, Petitioner was found guilty of two counts of rape. Before the Supreme Court was Petitioner’s third petition seeking to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Petitioner repeated the assertions contained in his first and second petitions, arguing that the prosecution fabricated evidence, that the evidence was insufficient to sustain the judgment, and that the trial court committed error in admitting the evidence. The Supreme Court denied relief, holding that, as with the first and second petitions, Petitioner had not stated a ground for the writ and that Petitioner’s successive application for coram-nobis relief was an abuse of the writ. View "Smith v. State" on Justia Law

Posted in: Criminal Law
by
After a jury trial, Appellant was convicted of four counts of fourth-degree sexual assault, possession of a firearm by a felon, two counts of fleeing, and resisting arrest. The court of appeals affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, arguing that the three attorneys who represented him at trial were ineffective. The trial court dismissed and denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the trial court was clearly erroneous in summarily denying postconviction relief. View "Magness v. State" on Justia Law

by
The district court found Appellant guilty of the offense of driving while intoxicated (DWI). On appeal, the circuit court affirmed, concluding that no culpable mental state was required for the DWI offense and that the stipulated facts provided sufficient evidence to demonstrate that Appellant had violated the Omnibus DWI Act of 1983. Appellant was sentenced to one day in jail. The Supreme Court reversed, holding that the circuit court erred in ruling that the Act does not require proof of a culpable mens rea, as provided in Ark. Code Ann. 5-2-203. View "Leeka v. State" on Justia Law

Posted in: Criminal Law
by
After a jury trial, Petitioner was found guilty of capital felony murder and sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed. Petitioner later filed a pro se petition seeking leave to proceed in the trial court with a petition for writ of error coram nobis, contending, among other things, 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 that Petitioner failed to establish a Brady violation, Petitioner’s assertions of trial error were outside the purview of a coram-nobis proceeding, and any issues concerning the sufficiency of the evidence or the credibility of witnesses also were not cognizable in a coram-nobis proceeding. View "Ventress v. State" on Justia Law

Posted in: Criminal Law
by
Petitioner filed a pro se petition for postconviction relief challenging a judgment of conviction entered against him. The trial court dismissed the petition. Petitioner filed a notice of appeal, which was not timely filed. Petitioner subsequently sought leave in the Supreme Court to proceed with a belated appeal of the order. The Supreme Court dismissed the motion because Petitioner's postconviction petition was not verified in accordance with Ark. R. Civ. P. 37.1(c), and as a result, the petition was not properly before the trial court. Petitioner sought rehearing or reconsideration of that decision. The Supreme Court treated the petition as a motion for reconsideration and denied the motion because Petitioner did not put forth any issues regarding an error of law or fact in the opinion denying his motion for belated appeal. View "Nutt v. State" on Justia Law

Posted in: Criminal Law
by
After a jury trial, Defendant was found guilty of possession of cocaine with intent to deliver, possession of marijuana with intent to deliver, and unauthorized use of property to facilitate a crime. The court of appeals affirmed. Defendant subsequently filed a petition for a new trial pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed the denial of Defendant’s Rule 37.1 petition, holding that the circuit court did not clearly err in refusing to grant relief on the points raised by Defendant. View "Smith v. State" on Justia Law

by
Appellant, an inmate, filed a petition for writ of habeas corpus alleging that the parole board denied him due process by failing to apply the statutorily mandated criteria for parole eligibility, failed to properly explain its reasons for denying Appellant parole, and incorrectly denied him parole. The circuit court denied the petition. Appellant lodged an appeal and filed two motions in which he sought and extension of time to file his brief and production of documents. The Supreme Court dismissed the appeal and declared the motions moot, holding that Appellant failed to raise a claim within the purview of a habeas action and therefore failed to meet his burden of demonstrating a basis for the writ to issue. View "Robinson v. Felts" on Justia Law

Posted in: Criminal Law
by
Petitioner filed a pro se petition for writ of mandamus alleging that Hon. Sam Pope, circuit judge of the Drew County Circuit Court, failed to timely provide a ruling on Petitioner's pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, which challenged his guilty plea to first-degree murder and his subsequent sentence of life imprisonment. In his mandamus petition, Petitioner requested an order directing the judge to rule on his Rule 37.1 petition. The Supreme Court denied the petition, holding that because Judge Pope stated good cause for the delay so far, the writ was not warranted. View "Pedraza v. Pope" on Justia Law

Posted in: Criminal Law
by
Appellant entered a plea of nolo contendere to aggravated residential burglary, first-degree domestic battering, and first-degree false imprisonment. Three years later, Appellant filed a pro se petition for writ of habeas corpus alleging that the judgment-and-commitment order entered in his criminal case was illegal on its face because he should have been convicted of only aggravated residential burglary and that the convictions for the other two offenses should be vacated. The circuit court denied the petition. The Supreme Court affirmed, holding that because the elements of aggravated residential burglary, first-degree domestic battering, and first-degree false imprisonment required proof of different elements, Appellant did not show that the judgment-and-commitment order was illegal on its face, and, further, the allegation did not call into question the trial court’s jurisdiction. View "Nelson v. State" on Justia Law

Posted in: Criminal Law