Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of aggravated robbery and theft of property. Defendant was sentenced as a habitual offender to a term of life imprisonment. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress evidence that the police seized after entering his motel room using a key card. The officers entered the motel room to serve an arrest warrant based on an anonymous tip. The Supreme Court affirmed, holding (1) the circuit court erred in admitting the evidence seized incident to Defendant’s arrest, as the uncorroborated tip, standing alone, did not provide sufficient detail for a reasonable belief that the motel room was Defendant’s room or that Defendant was present; but (2) the error in denying Defendant’s motion to suppress was harmless beyond a reasonable doubt. View "Evans v. State" on Justia Law

Appellant was convicted of capital murder and four counts of committing a terroristic act. The trial court imposed a total sentence of life imprisonment plus 120 months. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging, among other claims, ineffective assistance of counsel and trial error. The trial court dismissed the petition on the ground that it was not timely filed, but that order was vacated. Appellant subsequently sought an extension of time to file an amended petition. Thereafter, the trial court denied the original petition, noting that Appellant had failed to submit an amended petition. The Supreme Court dismissed Appellant’s appeal, holding that there was no merit to the Rule 37.1 petition. View "Allen v. State" on Justia Law

In 1983, Appellant pled guilty to ten counts of aggravated robbery and one count of robbery. For one of the aggravated-robbery convictions, Appellant was sentenced to life imprisonment. In 2010, the U.S. Supreme Court held in Graham v. Florida that a sentence of life without parole on a juvenile nonhomicide offense was unconstitutional. Appellant subsequently filed a petition for writ of habeas corpus alleging that his sentence of life imprisonment for aggravated robbery was illegal. After a hearing, the circuit court granted writ of habeas corpus and reduced Appellant’s life sentence to a sentence of forty years. Appellant appealed, arguing that a person resentenced under Graham is entitled to a plenary resentencing hearing. The Supreme Court rejected this argument in Hobbs v. Turner. The Supreme Court affirmed the sentence imposed by the circuit court and declined to overrule or modify its decision in Turner, as Appellant failed to give any compelling reason to do so. View "Proctor v. Hobbs" on Justia Law

Appellant was convicted of theft of property and two counts of aggravated robbery for robbing a bank. At trial, Appellant argued that he was involuntarily intoxicated at the time of the robbery due to the combination of prescription medications he was taking. Appellant sought postconviction relief alleging that he received ineffective assistance of counsel because his attorneys failed to subpoena certain prescription records from the pharmacy, failed to subpoena a pharmacy employee who could authenticate the records, and did not request a jury instruction on the lesser-included offense of robbery, resulting in Appellant’s conviction of the greater offense of aggravated robbery. The Supreme Court affirmed, holding (1) Appellant was not prejudiced by his attorneys’ failure to procure the records or testimony regarding the prescription records; and (2) Appellant’s second argument was not preserved for appeal. View "Feuget v. State" on Justia Law

Appellant entered a negotiated plea of nolo contendere to one count of theft of property-credit/debit card or account number and two counts of misdemeanor fraudulent use of a credit card. Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging that trial counsel provided ineffective assistance. The Supreme Court held that it must affirm on appeal where it was unable to determine whether the trial court’s findings were sufficient concerning Appellant’s claims because the record the record was insufficient concerning all of Appellant’s points on appeal. View "Carter v. State" on Justia Law

Appellant, an inmate, filed a pro se petition for writ of habeas corpus, arguing that the writ should issue on the ground that he would not have entered a plea of guilty in his criminal case if his attorney had correctly advised him on his eligibility for parole. The claim, however, did not call into question the trial court’s jurisdiction or the facial validity of the judgment. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal and mooted the motion filed in connection with the appeal, holding that Appellant failed to state a basis upon which the writ could issue. View "Sims v. State" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery. Though represented by counsel, Petitioner filed a timely pro se notice of appeal on his own behalf. The circuit court entered an on order admonishing Petitioner that, until his counsel was relieved as the attorney of record, Petitioner was not permitted to file any pro se pleadings on his own behalf. Petitioner subsequently tendered a partial record to the clerk of the Court of Appeals. The clerk declined to lodge the record. Petitioner’s counsel then filed in the Supreme Court a petition for writ of certiorari to complete the record and a motion to withdraw as counsel. The petition and motion were denied without prejudice, and no further action was taken by counsel to perfect the appeal. Before the Supreme Court here was Petitioner’s pro se motion to appoint new counsel. The Court granted the motion, appointed new counsel to represent Petitioner with this appeal, and issued a writ of certiorari to the circuit court to bring up the remainder of the record for the appeal. View "Mercouri v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of rape, three counts of sexual abuse in the second degree, and three counts of sexual indecency with a child. Appellant was sentenced to life imprisonment for each of the rape convictions. The Supreme Court affirmed in part and dismissed in part, holding (1) Appellant’s challenge to the denial of his motion to dismiss cannot be reached by the Court because Appellant changed the basis of his argument on appeal; (2) Appellant’s allegations of evidentiary errors are moot in light of the fact that the remedy for evidentiary errors is a new trial, and that remedy is not available to Appellant because he is deceased; and (3) the Court will not address Appellant’s argument that the circuit court erred in denying his motion for directed verdict because he changed his argument on appeal. View "Dowdy v. State" on Justia Law

After a jury trial, Appellant was found guilty of several criminal offenses. The Court of Appeals affirmed. The Supreme Court dismissed Appellant’s pro se petition for review. More than four years after the mandate was issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition on the ground that it was not timely filed under Ark. R. Crim. P. 37.2(c). Appellant then filed a notice of appeal and a motion to proceed in forma pauperis on appeal. The trial court denied the motion on the grounds that Appellant had no colorable cause of action that would entitle him to proceed as a pauper. Appellant appealed from both the order that denied the Rule 37.1 petition and the order that denied the motion to proceed in forma pauperis. The Supreme Court dismissed the appeal and declared the motion moot, holding (1) the trial court denied Appellant’s Rule 37.1 petition on the grounds of untimeliness, and (2) any issue regarding the denial of the motion to proceed in forma pauperis was moot. View "Williams v. State" on Justia Law

In 2012, Appellant was found guilty of rape and sexual indecency with a minor. An aggregate sentence of 480 months’ imprisonment was imposed. The Supreme Court affirmed. In 2014, Appellant filed a pro se petition for writ of habeas corpus, contending that he was not afforded effective assistance of trial counsel and that the evidence was insufficient to sustain the judgment of conviction. The circuit court denied relief, and Appellant appealed. The Supreme Court dismissed the appeal and declared moot the motion filed in connection to the appeal, holding that Appellant failed to state a basis on which the writ could issue. View "Pruitt v. State" on Justia Law