Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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