Justia Arkansas Supreme Court Opinion Summaries

Defendant pleaded guilty to first-degree murder, attempted first-degree murder and two sentencing enhancements. Thereafter, Defendant filed a petition seeking postconviction relief, asserting that he had entered the pleas as a result of ineffective assistance of counsel. The circuit court denied the petition without a hearing, finding that Defendant had failed to show that counsel was ineffective and in error. The Supreme Court reversed, holding (1) Defendant’s petition made sufficient allegations to create a question of fact that his counsel’s performance was deficient; and (2) the circuit court applied the wrong standard in reviewing Defendant’s petition. Remanded. View "Jones v. State" on Justia Law

Appellees, all of whom were imprisoned within the Arkansas Department of Corrections (ADC) system and under sentences of death, filed a complaint for declaratory judgment and injunctive relief, asserting, among other things, that Act 139 of 2013 unconstitutionally violates the separation of powers doctrine found in Ark. Const. art. IV because it permits the ADC to select any chemical within a class of chemicals known as barbiturates to effectuate a sentence of death by lethal injection. The Supreme court reversed, holding (1) Act 139 is not an unconstitutional violation of the separation of powers clause found in the Arkansas Constitution; and (2) the circuit court correctly found that Act 139 is not a sentencing statute and therefore does not violate the rule against retroactive application of sentencing statutes. View "Hobbs v. McGehee" on Justia Law

In 2005, Appellant entered pleas of guilty or nolo contendere to six counts of attempted capital murder and one count of arson. In 2014, Appellant filed a pro se petition for writ of habeas corpus, alleging that the trial court lacked jurisdiction in his case and that the judgment was illegal on numerous grounds. The petition was dismissed. The Supreme Court affirmed, holding that the circuit court did not err when it denied the petition, as Appellant did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction. View "Griffis v. Hobbs" on Justia Law

Appellant entered a negotiated plea of nolo contendere to manslaughter, manufacture of a controlled substance, abuse of a corpse, and tampering with physical evidence. Appellant later filed a pro se petition for writ of habeas corpus, alleging that he received ineffective assistance of counsel when he entered his plea of nolo contendere. The circuit court dismissed the petition with prejudice. The Supreme Court affirmed, holding that the circuit court correctly dismissed the petition because Appellant failed to demonstrate that the trial court in his case did not have subject matter jurisdiction or that the judgment was invalid on its face. View "Davis v. State" on Justia Law

Appellant entered a negotiated plea of guilty to murder in the first degree, aggravated robbery, first-degree escape and other charges stemming from his escape from a detention center after his attack on a correctional officer and his subsequent attacks on correctional officers at another facility. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his defense counsel provided ineffective assistance in several respects. The circuit court denied the petition without a hearing. The Supreme Court affirmed in part and reversed in remanded in part, holding that the findings and record did not conclusively show that Appellant was entitled to no relief on the first two of his claims. Remanded. View "Beverage v. State" on Justia Law

After a jury trial in 1982, Petitioner was found guilty of capital felony murder and first-degree battery. Petitioner was sentenced to life imprisonment. The Supreme Court affirmed. Petitioner subsequently sought leave from the Supreme Court to proceed in the trial court with a petition pursuant to Ark. R. Crim. P. 37.1. The Court denied the petition. In 2013, Petitioner filed a second petition to proceed under Rule 37.1, raising allegations of ineffective assistance of counsel. Because Petitioner did raise all issues for postconviction relief in the original petition, the petition was dismissed. Petitioner then filed a third petition to reinvest jurisdiction in the trial court to consider a petition under Rule 37.1. The Supreme Court dismissed the petition, holding that Petitioner was not entitled to proceed again under the Rule. View "Abernathy v. State" on Justia Law

Petitioner was convicted of capital murder, misdemeanor unauthorized use of a vehicle, possession of firearms by certain persons, and abuse of a corpse. Petitioner appealed, challenging the sufficiency of the evidence for the capital-murder charge. The Supreme Court reversed and dismissed the charge. Petitioner filed the instant petition for a writ of mandamus seeking to have the Supreme Court direct the circuit judge to enter a new or amended judgment reflecting the Court’s dismissal of the capital-murder charge. The Supreme Court denied the petition, holding that Petitioner failed to establish that the circuit judge was obligated to enter an amended judgment or that he failed to perform a duty imposed by the Court. View "Thornton v. Hon. Berlin Jones" on Justia Law

After a jury trial, Appellant was found guilty of rape, kidnapping, robbery, residential burglary, and third-degree battery. Appellant was sentenced as a habitual offender to an aggregate sentence of 1,320 months’ imprisonment. Appellant later filed a second 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. As grounds for the writ Appellant alleged that he was incompetent at the time of trial and was denied his right to present an insanity defense due to his attorney’s ineffectiveness and the State’s failure to reveal certain medical reports. The Supreme Court denied the petition, holding that Petitioner fell short of establishing a ground to issue a writ of error coram nobis. View "Hooper v. State" on Justia Law

Appellant was convicted of aggravated robbery and sentenced as a habitual offender to forty years’ imprisonment. The Supreme Court reduced the sentence to a term of twenty years because one of the prior judgments used to establish that Appellant was a habitual offender had been reversed on appeal. The next year, Appellant was found guilty of a separate robbery for which he was sentenced as a habitual offender to life imprisonment. Almost thirty years later, Appellant filed a pro se petition to correct sentence, alleging that his sentence of life imprisonment was illegal on its face and that his sentence of forty years’ imprisonment was facially invalid. The trial court denied the petition on the ground that it was not timely filed. The Supreme Court affirmed on different grounds, holding that the life sentence and the forty-year sentence were within the range allowed by statute and were not facially illegal. View "Halfacre v. State" on Justia Law

After a jury trial, Appellant was found guilty of commercial burglary, theft of property, and fraud. Appellant was sentenced as a habitual offender to serve an aggregate term of 1,200 months’ imprisonment. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied relief after a hearing. The Supreme Court affirmed, holding (1) the trial court did not err in correcting the sentencing order to reflect that Appellant was sentenced as a habitual offender under Ark. Code Ann. 5-4-501(b) rather than section 5-4-501(a); and (2) Appellant’s counsel did not provide ineffective assistance. View "Fletcher v. State" on Justia Law