Justia Arkansas Supreme Court Opinion Summaries

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

Appellant pleaded guilty to aggravated robbery and was sentenced to 240 months’ imprisonment. Appellant filed a pro se petition for writ of habeas corpus, apparently asserting a claim of ineffective assistance of counsel and referring to the sentencing order and to the standard for determining when a writ of habeas corpus should issue. The circuit court denied the petition, finding that Appellant’s allegations were conclusory. Appellant appealed, making several allegations of error. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition because Appellant’s allegations were either not cognizable in a habeas proceeding or conclusory statements that provided no basis for granting habeas relief. View "Dunbar v. State" on Justia Law

Appellant entered a plea of guilty to first-degree battery of a child in violation of Ark. Code Ann. 5-13-201(a)(9). Appellant was sentenced to 480 months imprisonment. Thereafter, Appellant filed a pro se petition to correct the sentence imposed, arguing that his sentence was illegal because it exceeded the sentence prescribed in the Arkansas Sentencing Commission Guidelines. The trial court denied the petition. Appellant appealed. The Supreme Court dismissed the appeal, holding that the sentence was not illegal because it was within the range set by statute, and therefore, Appellant was not entitled to relief. View "Canada v. State" on Justia Law

After a jury trial in 1989, Appellant was found guilty of murder in the first degree and sentenced as a habitual offender to 200 years’ imprisonment. In 2000, Appellant filed a pro se petition for writ of habeas corpus alleging that the 200-year sentence exceeded the statutory maximum sentence for first-degree murder and was thus illegal. The Supreme Court denied the petition, holding that the sentence was within statutory range. In 2014, Appellant filed a pro se petition for writ of habeas corpus, raising seven claims. The circuit court denied the petition. the Supreme Court affirmed, holding (1) Appellant’s claim that his sentence was excessive had already been addressed; and (2) the remaining allegations raised by Appellant were not cognizable in a habeas proceeding. View "Scott v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and aggravated robbery. Appellant was sentenced to life imprisonment without parole for the capital-murder conviction. On appeal, Appellant argued that the circuit court erred in denying his motion for directed verdict and in refusing to submit to the jury his proffered verdict forms on accomplice liability. The Supreme Court affirmed, holding (1) because in Appellant’s general motion for a directed verdict made at trial he did not raise the specific issues he raised on appeal, the Court was precluded from reviewing the sufficiency of the evidence on appeal; and (2) Appellant’s second argument could not be considered on appeal because he failed to support it with cogent argument or citation to relevant authority. View "Perry v. State" on Justia Law

In 2003, Appellant pleaded guilty to second-degree sexual assault. In 2014, Appellant filed a pro se motion asking that a prison bond be set and that he be granted a pardon. The trial court denied the motion. Appellant then filed a second motion seeking to have bond set and a pardon granted and a motion asking the court to press charges on two persons that made false accusations against him in 2002. These two motions were also denied. The Supreme Court dismissed Appellant's appeal, holding that all three motions filed by Appellant, which the Court considered as requests for postconviction relief pursuant to Ark. R. Crim. P. 37.1, were not timely filed. View "Parker v. State" on Justia Law

After a jury trial, Appellant was found guilty of sexual indecency with a child and sexual assault in the second degree. After the conviction was affirmed on appeal, Appellant filed a petition for postconviction relief, alleging, among other things, that his counsel provided ineffective assistance. The trial court dismissed the petition, concluding that it was untimely filed. This appeal concerned Appellant’s third pro se petition for postconviction relief in which he made essentially the same allegations as he raised in his first postconviction petition. The trial court denied and dismissed the petition, ruling that Appellant could not file a subsequent petition for postconviction relief when a postconviction petition alleging essentially the same claims had already been denied as being untimely. The Supreme Court affirmed, holding that because Appellant did not appeal from the order dismissing his first petition as untimely, his third petition was likewise untimely, and the trial court had no jurisdiction to grant the relief sought. View "Newton v. State" on Justia Law

In 2011, Appellant pleaded guilty to second-degree battery. While the judgment-and-commitment order reflected that Appellant was sentenced to serve ninety-six months’ imprisonment for the offense, the order was not appropriately marked to indicate that Appellant was sentenced as a habitual offender. This appeal concerned Appellant’s third petition to correct an illegal sentence, in which he contended that his sentence was outside the statutory range for second-degree battery, and therefore, the sentence was illegal on its face. The trial court denied the petition. The Supreme Court affirmed, holding that the failure to appropriately indicate on the judgment-and-commitment order that Appellant was sentenced as a habitual offender was clerical error that did not result in an illegal sentence. Remanded with instructions for the trial court to enter a corrected judgment-and-commitment order reflecting that Appellant was sentenced as a habitual offender. View "Esry v. State" on Justia Law