Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that the evidence was insufficient to support his conviction and that his counsel provided ineffective assistance. The trial court denied the petition. The Supreme Court dismissed the appeal, holding (1) challenges to the sufficiency of the evidence are not cognizable under Rule 37.1; and (2) Appellant’s allegations of ineffective assistance did not meet the standard under Washington v. Strickland for establishing ineffective assistance of counsel. View "Leach v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of rape. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging that he was not afforded the effective assistance of counsel. The trial court denied the petition, concluding that counsel’s performance was not ineffective. Appellant appealed and sought by pro se motion an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Appellant failed to establish that his trial counsel provided constitutionally defective assistance. View "Johnston v. State" on Justia Law

After a jury trial, Defendant was found guilty of possession of cocaine with intent to deliver and resisting arrest. The resisting arrest charge was merged into the possession charge and Petitioner was sentenced, as a habitual offender, to a term of forty years’ imprisonment. The court of appeals affirmed. Here, Petitioner filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that one of the officers who arrested him planted drugs on him. The Court denied the petition, holding that Petitioner failed to present a claim that supported a meritorious attack on the judgment. View "Johnson v. State" on Justia Law

After a jury trial, Petitioner was found guilty of capital murder and battery in the first degree. Petitioner was sentenced to an aggregate sentence of life imprisonment without parole. The Supreme Court affirmed. Thereafter, Petitioner filed a petition for postconviction relief, which was denied. Petitioner later filed a third petition requesting that the Supreme Court reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of error coram nobis, raising several allegations of error. The Supreme Court denied the petition, holding that Petitioner failed to establish a basis for the writ because he failed to offer any factual substantiation from which it could be determined that there was a ground for the writ. View "Grant v. State" on Justia Law

In 2004, Appellant entered a nolo contendere plea to a charge of rape and a charge of incest. In 2014, Appellant filed a pro se petition for writ of habeas corpus, arguing that the writ should issue on the ground that a jury was empaneled for his trial but that he was declared guilty in a bench trial and that he did not waive his right to trial by jury. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant did not allege a basis on which the circuit court could properly grant a writ of habeas corpus. View "Chance v. State" on Justia Law

In 1979, Appellant entered a negotiated plea of guilty to attempted capital murder and was sentenced to life imprisonment. Appellant was seventeen when he committed this offense. In 2011, Appellant filed a pro se complaint for declaratory relief alleging that the parole-eligibility statute was unconstitutional as applied to him. Relying on Graham v. Florida, Appellant requested that the circuit court find that his life sentence violated the Eighth Amendment and that he be resentenced to a term of years. The circuit court dismissed the action on summary judgment. Appellant appealed. The Supreme Court reversed, holding that, under Arkansas law, attempted capital murder is not a homicide offense for purposes of Graham. Remanded. View "Bramlett v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted of capital felony murder and aggravated robbery, with a firearm enhancement on each count. Appellant was sentenced to life imprisonment without the possibility of parole for the murder. The Supreme Court affirmed. Appellant subsequently filed an Ark. R. Crim. P. 37.1 petition, alleging that his defense counsel provided ineffective assistance. The circuit court denied the petition. Appellant appealed. The Supreme Court dismissed the appeal on the grounds that Appellant’s petition was not in compliance with Rule 37.1 because there was no verification that the facts stated in the petition were true, correct, and complete. View "Bradley v. State" on Justia Law

Appellant pled no contest to two misdemeanors and one Class D felony. At the time of his sentencing, the Community Punishment Act (CPA) allowed Appellant to petition the court to expunge the record of his offense upon the successful completion of probation. Subsequent to Appellant’s sentencing, the General Assembly passed the Comprehensive Criminal Record Sealing Act (CCRSA), which amended the CPA so that the procedure for sealing records under the CPA would be in accordance with the CCRSA. Less than three weeks after the CCRSA became effective, Appellant completed his felony probation and petitioned the circuit court to seal all of his records. The circuit court denied the petition, concluding that Appellant was required to wait five years after completing his probation before the records could be sealed under the CCRSA. The Supreme Court reversed, holding that the circuit court erred in retroactively applying the CCRSA to Appellant’s felony conviction because the legislature did not intend for the CCRSA to apply retroactively to Appellant’s felony conviction. Remanded for the court to apply the CPA to Appellant’s felony conviction and the CCRSA to his misdemeanor convictions. View "Bolin v. State" on Justia Law

Appellant pleaded guilty to rape and was sentenced to 240 months’ imprisonment. Appellant later filed two pro se motions entitled “Motion for a State of Duress.” The trial court denied both motions. The motions consisted collateral challenges to the judgment mixed with direct challenges to the judgment that should have been raised at the time Appellant entered his plea. The Supreme Court affirmed, holding (1) to the extent that Appellant raised claims cognizable under Ark. R. Crim. P. 37.1, the motions were not timely filed; and (2) with respect to those claims that were a direct challenge to the judgment, these issues did not present a cause for granting postconviction relief, as the issues could have been settled in the trial court at the time Appellant entered his plea. View "Winnett v. State" on Justia Law

Petitioner filed a pro se petition for leave to proceed in forma paupers with respect to a petition for judicial review. Also tendered for filing was Petitioner’s proposed order granting leave to proceed in forma pauperis. The circuit court denied the petition, but there was no effective order made. Petitioner sought to appeal and filed a petition to proceed in forma pauperis with the filing of a motion for rule on clerk. The Supreme Court denied the petition, as there was no effective order from which Petitioner may appeal. View "Ehler v. Post-Prison Transfer Bd." on Justia Law