Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

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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

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

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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

Posted in: Criminal Law