Justia Arkansas Supreme Court Opinion Summaries

Appellant pleaded guilty to multiple felony offenses. Appellant subsequently filed a timely pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court dismissed the petition on the ground that it did not comply with Rule 37.1(b). Appellant did not appeal from the order that dismissed his petition but instead filed a second petition for postconviction relief under Rule 37.1. The trial court denied relief on the ground that a second petition was not authorized under the Rule. Appellant appealed, arguing that there was good cause for his failure to file a conforming petition, and therefore, his should have been permitted to proceed with a second petition that conformed with the Rule. The Supreme Court affirmed, holding that Appellant did not demonstrate that he was entitled to file a subsequent petition. View "Smith v. State" on Justia Law

In 2009, Appellant was convicted of rape, sexual indecency with a child, and possessing matter depicting sexually explicit conduct involving a child. The Arkansas Department of Correction (ADC) applied Ark. Code Ann. 16-93-611 to Appellant’s sentence for the crime of rape to determine his parole-eligibility date. The court of appeals affirmed. In 2013, Appellant filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the ADC, arguing that the application of section 16-93-611(a)(1) to his sentence was an unconstitutional sentence enhancement and that he was denied due process of law by the application of the statute without notice. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because the arguments raised by Appellant in this appeal primarily stemmed from his erroneous characterization of section 16-93-611 as an enhancement statute, none of the claims for relief in Appellant’s petition demonstrated that he was entitled to any relief by means of a declaratory judgment or a writ of mandamus. View "Mason v. Hobbs" on Justia Law

Petitioner was convicted of committing a terroristic act, criminal attempt to commit first-degree battery, and four counts of aggravated assault. The court of appeals affirmed. Petitioner subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37.1. The trial court denied the petition, but the circuit court clerk failed to promptly notify Petitioner of the order. Petitioner appealed belatedly and filed a motion for belated appeal. The Supreme Court granted the motion, holding that Petitioner had good cause for the delay in filing the notice of appeal. View "Lee v. State" on Justia Law

Appellant filed a motion for a hearing on the denial of a request that he had made to the Arkansas State Crime Laboratory under the Freedom of Information Act. The circuit court dismissed the complaint based on Ark. Code Ann. 16-68-607 - otherwise known as the three-strike rule - which lists as “strikes” three previous actions that have been dismissed. The Supreme Court reversed the dismissal, holding that one of the three cases that the circuit court had relied on in determining that Appellant had received three strikes should not have been counted as a strike against him. Remanded. View "Hill v. Gallagher" on Justia Law

In 1986, a judgment of conviction was entered wherein Petitioner was found guilty of aggravated robbery and sentenced as a habitual offender to life imprisonment. Before the Supreme Court here was Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition under the version of Ark. R. Crim. P. 37.1 in effect when Petitioner became eligible to file a petition, alleging that the judgment was illegal in his case. The instant petition was the fourth request filed by Petitioner in the Court seeking Rule 37.1 relief pertaining to his criminal case. The Supreme Court dismissed the petition, holding that Petitioner was prohibited from filing another petition under Rule 37.1. View "Halfacre v. State" on Justia Law

In 2008, Appellant entered guilty pleas to first-degree terroristic threatening, second-degree sexual assault, and having violated the terms of a suspended imposition of sentence. Appellant did not appeal his convictions. In 2014, Appellant filed in the trial court a petition for writ of error coram nobis. The trial court denied the petition on the basis that the Supreme Court had not granted permission for Appellant to proceed in the trial court. The Supreme Court affirmed the denial of the petition, holding that the circuit court erred in its rationale but that Appellant failed to demonstrate that he was entitled to the writ. View "Green v. State" on Justia Law

In 2013, Defendant was convicted of three counts of rape, three counts of aggravated robbery, and one count of Class B felony kidnapping. Defendant’s convictions arose from three separate incidents that occurred in January, 2001. Defendant appealed, arguing that the abolition by Ark. Code Ann. 5-1-109(b)(1)(B) and (j) of the statute of limitations defense for defendants whose DNA profile is included in a DNA database violates the Equal Protection Clause. The Supreme Court affirmed, holding that the statutory provisions eliminating the statutes of limitation for DNA-identified defendants do not violate Defendant’s right to equal protection. View "Brown v. State" on Justia Law

After a jury trial, Appellant was found guilty of murder. The Supreme Court affirmed. Appellant then filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition after conducting an evidentiary hearing. Appellant appealed the denial of his postconviction petition. The Supreme Court affirmed, holding (1) there was no error in the adequacy of the order issued by the trial court in support of its findings dismissing Appellant’s petition; and (2) the trial court did not err in finding that Defendant received constitutionally effective assistance of counsel. View "Anderson v. State" on Justia Law

On July 9, 2012, Petitioner filed in the circuit court a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Petitioner then filed this pro se petition for writ of mandamus seeking to have the circuit judge enter a final order on the Rule 37.1 petition. In his response, the circuit judge stated that he was unaware that the final order was never entered until this mandamus action was filed. The circuit court appended to the response a copy of the final order denying the Rule 37.1 petition that was subsequently entered. Because the circuit judge acted on the petition, this mandamus action was rendered moot. However, the Supreme Court took the opportunity to urge all judicial districts to ensure that judges are aware of the state of the docket for all cases in their courts. View "Leach v. Looney" on Justia Law

Appellant was arrested based on a violation of drug laws. Cash in the amount of $5093 was recovered from Appellant’s vehicle at the time of his arrest. The prosecuting attorney filed an in rem complaint on behalf of the State seeking the condemnation and forfeiture of the $5093. The circuit clerk issued a summons. Appellant did not respond to the complaint, and the circuit court subsequently granted the State’s motion for default judgment and ordered the forfeiture of the $5093. Thereafter, Appellant filed a complaint against the prosecuting attorney, the circuit clerk, and the circuit judge who presided in the forfeiture action, collaterally attacking the judgment. The circuit court dismissed the complaint with prejudice. The Supreme Court affirmed, holding that the circuit judge and the prosecuting attorney had absolute immunity from suit and that Appellant abandoned on appeal any claim against the circuit clerk. View "Hall v. Jones" on Justia Law