Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of capital-felony murder in Arkansas and sentenced to life imprisonment without the possibility of parole. Appellant filed a petition for writ of habeas corpus in the Jefferson County Circuit Court, arguing that, because he was seventeen years old at the time of the crime, his sentence violated the Eighth Amendment’s prohibition against cruel and unusual punishment. At the time he filed his petition, Appellant was incarcerated in a correctional facility in New Jersey. Appellant argued that because he was incarcerated under the terms of the Interstate Corrections Compact (ICC), he remained in the custody of the Director of the Arkansas Department of Correction (ADC), which is headquartered in Jefferson County, for the purpose of the state’s habeas corpus statutes. The circuit court dismissed the petition, concluding that it lacked jurisdiction to issue a writ and make it returnable in Jefferson County. The Supreme Court reversed, holding (1) the terms of the ICC supplement the state’s ordinary habeas jurisdictional analysis; and (2) Jefferson County had jurisdiction over Appellant’s petition for writ of habeas corpus. Remanded. View "Hundley v. Hobbs" on Justia Law

Appellant pleaded guilty to a single count of rape pursuant to a plea agreement. Appellant was sentenced to twenty-five years in prison, the minimum sentence he could have received, plus a suspended imposition of sentence of fifteen years. Appellant filed a petition pursuant to Ark. R. Crim. P. 37 alleging that his counsel had provided ineffective assistance by advising him that he would be eligible for parole in five years and would serve no more than eight years and that he would have refused to plead guilty had he known he would be required to serve at least seventy percent of his sentence before becoming eligible for parole. The circuit court denied the petition, concluding that Appellant had been correctly advised about his eligibility for parole. The Supreme Court affirmed, holding that the circuit court did not clearly err in determining that Appellant did not receive incorrect advice regarding his eligibility for parole. View "Riddle v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to death. In Ward I, the Supreme Court affirmed Petitioner’s conviction for capital murder but reversed his death-penalty sentence and remanded for resentencing. Petitioner filed this motion to recall the mandate in Ward I, arguing that a recall was warranted because there was a defect or breakdown in the appellate process when the Court failed to recognize the circuit court’s violation of Ake v. Oklahoma and appellate counsel failed to raise the issue in Petitioner’s direct appeal. The Supreme Court denied the motion, holding that Petitioner failed to establish a breakdown in the appellate process that warranted a recall of the mandate in Ward I. View "Ward v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to death. After the Supreme Court twice reversed Petitioner’s sentence, a third jury again sentenced Petitioner to death. The Supreme Court affirmed the sentence on appeal in Ward III. After Petitioner unsuccessfully sought relief under Ark. R. Crim. P. 37.1 and unsuccessfully petitioned to reinvest jurisdiction in the circuit court to consider a petition for a writ of error coram nobis, Petitioner filed a motion to recall the mandate in Ward III. In support of his motion, Petitioner identified two issues that he asserted amount to a defect or breakdown in the appellate process sufficient to justify recalling the mandate. The Supreme Court denied the motion, holding that the record demonstrated that a breakdown in the appellate process in Ward III did not occur and there was nothing to be remedied by recalling the mandate. View "Ward v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to death. After the Supreme Court twice reversed Petitioner’s sentence, a third jury again sentenced Petitioner to death. The Supreme Court affirmed the sentence on appeal. Petitioner subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5. The circuit court denied the petition after a hearing. The Supreme Court affirmed in Ward IV. Petitioner then moved the Supreme Court to recall the mandate in Ward IV, identifying three issues that he suggested amounted to a defect or breakdown in the appellate process sufficient to justify recalling the mandate. The Supreme Court denied the motion, holding that Petitioner failed to establish a defect or breakdown in the appellate process sufficient to support recalling the postconviction appeal mandate. View "Ward v. State" on Justia Law

In 2008, Appellant entered a guilty plea to first-degree battery and being a felon in possession of a firearm. In 2014, Appellant filed a pro se “Motion to Enforce Guilty Plea Agreement” alleging that his counsel did not obtain the correct information regarding his sentence and that the Arkansas Department of Correction (ADC) improperly changed and enhanced his sentence by calculating his parole-eligibility date in a way that did not conform to the plea agreement. The trial court denied the motion on the ground that it was an untimely petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The Supreme court dismissed the appeal, holding (1) to the extent Appellant’s claims could be construed as a challenge to the ADC’s actions, the challenge was not cognizable in a motion for relief filed in the trial court; and (2) to the extent Appellant’s claims could be construed as allegations of ineffective assistance of counsel, a request for modification of his sentence, or for vacation of the judgment, the motion fell within the purview of Rule 37.1 and was untimely filed. View "Watson v. State" on Justia Law

Appellant pleaded guilty to one count of rape and was sentenced to life imprisonment. Appellant later filed a petition for writ of error coram nobis, alleging that he was insane at the time he entered his guilty plea and that his guilty plea was coerced. The circuit court denied the petition without conducting a hearing. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in denying the petition without a hearing where (1) Appellant failed to show that there existed some fact that would have prevented rendition of judgment had it been known to the trial court and that was not brought forward before rendition of judgment; and (2) Appellant’s claim of ineffective assistance of counsel was not cognizable in error coram nobis proceedings. View "Westerman v. State" on Justia Law

Appellant entered a plea of guilty to kidnapping and stalking in the first degree and was sentenced to serve an aggregate sentence of 180 months’ imprisonment. Two years later, Appellant filed a motion to withdraw the guilty plea, which constituted a request for postconviction relief under Ark. R. Crim. P. 37.1. The trial court denied the motion. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging that he was coerced into pleading guilty and that his counsel incorrectly informed him that he would be eligible for parole after serving one-third of his sentence. The trial court rejected the allegations as grounds for issuance of a writ of error coram nobis. The Supreme Court affirmed, holding that Appellant failed to state a ground for the writ. View "Wright v. State" on Justia Law

Appellant entered a negotiated plea of no contest to a charge of aggravated residential burglary and negotiated pleas of guilty to aggravated assault and felon in possession of a firearm. The circuit court accepted the pleas. Appellant subsequently filed a petition for postconviction relief alleging that he did not knowingly and voluntarily enter the pleas and that he received ineffective assistance of counsel in accepting the negotiated pleas. The circuit court rejected Appellant’s claims. The Supreme Court affirmed, holding that the circuit court did not err in (1) finding that Appellant voluntarily and knowingly entered pleas of no contest and guilty; and (2) concluding that Appellant received effective assistance of counsel. View "Young v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of capital murder. Petitioner was sentenced to two concurrent terms of life imprisonment without parole. The Supreme Court affirmed. This appeal concerned Petitioner’s second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Petitioner asked that the petition be considered in the alternative as a petition to proceed in the trial court under Ark. R. Crim. P. 37.1, or a motion to recall the Supreme Court’s mandate on direct appeal, or a petition for writ of certiorari. The Supreme Court denied the petition, holding (1) Petitioner was not required to obtain the Court’s permission before filing a Rule 37.1 petition in the trial court; (2) Petitioner did not show that certiorari will lie to provide a remedy for any of the issues raised in the instant petition; (3) Petitioner was not entitled to recall of the mandate; and (4) regarding Petitioner’s request to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, Petitioner failed to state a ground for the writ. View "Rhoades v. State" on Justia Law