Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of raping his stepdaughter. The court of appeals affirmed. Petitioner subsequently filed a pro se petition for relief under Ark. R. Crim. P. 37, alleging a number of grounds for relief. The circuit court denied the petition with a hearing. The Supreme Court reversed for an evidentiary hearing regarding the issue of whether Appellant received ineffective assistance of counsel when his attorney failed to introduce an audio recording of a message left for Appellant by his stepdaughter and her mother. The circuit court again denied Appellant’s petition, concluding that trial counsel’s decision was a matter of strategy and trial tactics. The Supreme Court affirmed, holding that the circuit court’s denial of Appellant’s petition was not clearly erroneous. View "Lemaster v. State" on Justia Law

After a jury trial, Petitioner was found guilty of rape and sentenced to 300 months’ imprisonment. The court of appeals affirmed. Petitioner later filed a pro se petition in the Supreme Court seeking leave to proceed in the trial court with a petition for writ of error coram nobis. The Court denied the petition. Petitioner then filed this petition asking to have jurisdiction reinvested in the trial court to consider a coram-nobis petition, alleging, inter alia, that the prosecution withheld exculpatory evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) Petitioner did not establish that there was evidence withheld that met the threshold requirements of a Brady violation that was both material and prejudicial; and (2) Petitioner’s remaining claims of error were outside the purview of a coram-nobis proceeding. View "Johnson v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of aggravated robbery and one count of first-degree battery. The court of appeals affirmed. Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied the petition. Appellant then filed a motion for modification or reconsideration of the trial court’s order. The trial court denied the motion, addressing Appellant’s claims that had not been addressed in the order denying postconviction relief. Appellant appealed the trial court’s order denying his petition. The Supreme Court affirmed, holding that the trial court did not clearly err in denying postconviction relief. View "Carter v. State" on Justia Law

Petitioner was found guilty in one case of aggravated robbery and misdemeanor theft of property. Petitioner was also found guilty in another case that same year of being a felon in possession of a firearm, filing a false report with law enforcement, and misdemeanor fleeing. The court of appeals affirmed the judgment in both cases in one decision. Petitioner subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied relief in each case. Petitioner filed a motion for belated appeal concerning the order in the first case. The Supreme Court treated the motion as motion for rule on clerk and denied the motion because Petitioner failed to perfect his appeal in accordance with the prevailing rules of procedure and failed to state good cause for failure to comply with the procedural rules. View "Butler v. State" on Justia Law

Appellant pleaded guilty to first-degree battery of a law enforcement officer acting in the line of duty and possession of a firearm by certain persons. Appellant later filed a petition for writ of error coram nobis in the circuit court alleging that he was denied effective assistance of counsel, causing him to accept a plea that was not “knowingly entered upon advice of counsel” and to acknowledge that his recourse was the filing of a petition under Ark. R. Crim. P. 37. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s petition for writ of error coram nobis did not state a cognizable claim for relief. View "White v. State" on Justia Law

Appellant entered a negotiated plea of guilty to two counts of robbery and was sentenced as a habitual offender to consecutive sentences of 300 months’ imprisonment for the first count and 300 months’ suspended imposition of sentence for the second count. Appellant subsequently filed a pro se petition for writ of habeas corpus in the circuit court, alleging that his sentence was illegal because a suspended sentence imposed with a term of imprisonment for a different crime must run concurrently. The Supreme Court agreed with Appellant and reversed, holding that the trial court did not have the authority to order that the sentence of 300 months’ imprisonment run consecutively to the 300 months’ suspended imposition of sentence. View "Walker v. State" on Justia Law

Appellant pleaded guilty to charges of possession of a controlled substance and possession of drug paraphernalia. Appellant appealed, arguing that the circuit court erred by denying his motion to suppress evidence seized following a traffic stop of his vehicle, claiming that the stop was illegal. The court of appeals affirmed. The Supreme Court reversed the circuit court’s sentencing order and vacated the opinion of the court of appeals, holding that the stop was not based on a reasonable suspicion that Appellant was engaged in criminal activity, and therefore, the circuit court erred by denying Appellant’s motion to suppress. View "Schneider v. State" on Justia Law

In 1992, Petitioner entered a plea of guilty to capital-felony murder and was sentenced to life imprisonment without parole. The Supreme Court dismissed Petitioner’s direct appeal. Thereafter, Petitioner was party to numerous cases involving his guilty plea. Petitioner was unsuccessful in each of these cases and was equally unsuccessful in seeking federal habeas relief. In 2014, Petitioner filed a petition to reinvest jurisdiction with the circuit court to hold a hearing on his petition for writ of error coram nobis, alleging, among other things, that he was unaware that his plea was not voluntarily, knowingly, or intelligently made until his present attorney advised him. The Supreme Court denied the petition, holding that none of Petitioner’s claims fell within one of the four recognized categories subject to coram-nobis relief. View "Noble v. State" on Justia Law

Petitioner was found guilty of rape and was sentenced to life imprisonment. Counsel for Petitioner timely filed an appeal from that verdict. The appeal remained pending at the time Petitioner filed this pro se petition asking that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging, among other claims, that he was entitled to coram-nobis relief because the trial court rather than the jury fixed his punishment, the trial court failed to rule on a number of defense motions, and that he was not afforded a fair trial. The Supreme Court denied the petition, holding that Petitioner was not entitled to coram-nobis relief, as none of the allegations of error was such that it could not have been settled at trial. View "McClinton v. State" on Justia Law

Appellant entered a plea of nolo contendere to a single count of sexual assault in the first degree. The circuit court accepted the plea and sentenced Appellant to eight years in prison. Appellant subsequently filed a motion to withdraw his plea pursuant to Ark. R. Crim. P. 26.1, asserting that he had received ineffective assistance of counsel and that he did not voluntarily enter the nolo contendere plea. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the withdrawal of his plea of nolo contendere was necessary to avoid a manifest injustice, and therefore, the circuit court did not abuse its discretion by denying Appellant’s motion to withdraw his plea. View "Martin v. State" on Justia Law