Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Arnett v. Hobbs
In 2009, Appellant was convicted of murder in the second degree and abuse of a corpse. Appellant was sentenced to an aggregate sentence of 360 months’ imprisonment. In 2010, Appellant was convicted of two misdemeanors and sentenced to an aggregate sentence of twelve months’ imprisonment. In 2013, Appellant filed a petition for writ of habeas corpus challenging the misdemeanor judgments. The circuit court denied the petition. The Supreme Court affirmed, holding that because Appellant did not demonstrate that he was in custody pursuant to the 2010 misdemeanor judgments, he did not establish a ground for a writ of habeas corpus to effect his release from custody. View "Arnett v. Hobbs" on Justia Law
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Criminal Law
Standridge v. State
After a jury trial, Defendant was convicted of Class D felony violating an order of protection and sentenced to fifty-four months in prison. The Supreme Court reversed and dismissed Defendant’s conviction, holding that the circuit court lacked subject matter jurisdiction to try Defendant on the charge because it was not a criminal offense. Specifically, the Court concluded that the State charged and tried Defendant under Ark. Code Ann. 9-15-207, which was not a criminal statute. Therefore, Defendant’s charge and trial were not based on a criminal offense, and the circuit court lacked subject matter jurisdiction over the matter. View "Standridge v. State" on Justia Law
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Criminal Law
Russell v. State
After a jury trial, Appellant was found guilty of second-degree battery and the offense of being a felon in possession of a firearm. The court of appeals affirmed. Appellant later timely filed a verified pro se petition for postconviction relief challenging the judgment. The trial court denied the petition, concluding that it lacked jurisdiction to consider it. However, the court gave no reason for dismissing the petition. The Supreme Court reversed and remanded the matter so that the trial court may enter an order setting out the basis for the dismissal of the petition. View "Russell v. State" on Justia Law
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Criminal Law
Morrow v. State
Defendant pleaded guilty to second-degree sexual assault. Appellant was sentenced to ten years’ probation and subject to sex-offender-registration requirements. The next year the State filed a felony information alleging that Defendant had failed to comply with registration and reporting requirements. The circuit court found Defendant guilty of the offense of failure to comply with the registration and reporting requirements of Ark. Code Ann. 12-12-904. The Supreme Court affirmed, holding that the circuit court did not err in denying Defendant’s motion to dismiss, as (1) the State was not required to prove any culpable-mental-state element of the offense; and (2) the State provided sufficient evidence of what address Defendant had registered with the local law enforcement agency responsible for monitoring sex-offender registration. View "Morrow v. State" on Justia Law
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Criminal Law
Johnson v. State
In 1997, Appellant entered a negotiated plea of guilty to first-degree murder and aggravated assault. Pursuant to Ark. Code Ann. 16-93-611, in effect at the time Appellant committed the offenses, a person found guilty of first-degree murder was not eligible for parole until he served seventy percent of his sentence. In 1999, section 16-93-611 was amended to allow the trial court to waive the seventy-percent requirement if the defendant was a juvenile at the time of the offense. At the time he committed the offenses, Appellant was fourteen years old. In 2013, Appellant filed a motion seeking waiver of the seventy-percent requirement, arguing that the trial court had jurisdiction to retroactively apply section 16-93-611 as amended to waive the requirement. The trial court denied the motion, concluding that it no longer had jurisdiction in the matter because the motions were not filed ninety days after the entry of judgment. The Supreme Court affirmed, holding that Appellant’s motion was untimely. View "Johnson v. State" on Justia Law
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Criminal Law
Hubbard v. Hobbs
After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, claiming actual innocence, challenging the sufficiency of the evidence to support his conviction, and alleging that the circuit court lacked subject-matter jurisdiction to retry his case because of a speedy-trial violation. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish a basis for a finding that a writ of habeas corpus should issue. View "Hubbard v. Hobbs" on Justia Law
Sims v. Hobbs
Appellant filed a pro se petition for writ of habeas corpus, contending that the evidence was insufficient to sustain his criminal conviction, the prosecutor committed misconduct at trial, he was denied his right to a fair trial before an impartial judge, and he was denied effective assistance of counsel. The circuit court denied the petition. Appellant lodged an appeal and filed motions for appointment of counsel and for leave to file a belated reply brief. The Supreme Court dismissed the appeal and declared the motions moot, holding that Appellant failed to state a basis on which the writ could issue, and therefore, the circuit court did not err in denying relief. View "Sims v. Hobbs" on Justia Law
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Criminal Law
Hinkston v. State
After a jury trial, Appellant was found guilty of capital murder, residential burglary, and theft of property. Appellant was sentenced to life without parole for capital murder. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, raising several claims. The circuit court denied the habeas petition. Appellant lodged an appeal from that order and then filed a motion for appointment of counsel to represent him on appeal. The Supreme Court dismissed the appeal and declared the motion moot, holding that Appellant failed to raise a claim within the purview of a habeas action and therefore failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Hinkston v. State" on Justia Law
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Criminal Law
Airsman v. State
After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment, plus fifteen years for a firearm enhancement. The Supreme Court affirmed the convictions and sentence, holding (1) there was substantial evidence to support Appellant’s conviction for first-degree murder, and the circuit court did not err in denying Appellant’s motion for directed verdict; (2) the circuit court did not err in denying Appellant’s motion to suppress his statements; and (3) the circuit court did not err in denying Appellant’s motion in limine to exclude certain photographs that Appellant claimed were irrelevant and more prejudicial than probative.` View "Airsman v. State" on Justia Law
Willams v. Hobbs
In 2008, Appellant was convicted of rape. In 2014, Appellant, who was incarcerated, filed a pro se petition for writ of habeas corpus, arguing, among other things, that while the offense for which he was convicted occurred in Chicot County, he entered his guilty plea in Desha County, making the sentence imposed illegal. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to substantiate a claim within the purview of a habeas action, as (1) Appellant did not show, by affidavit or other evidence, that he was illegally detained; and (2) Appellant’s claim that the DNA testing in his case was incomplete did not implicate the facial validity of the judgment or the jurisdiction of the trial court. View "Willams v. Hobbs" on Justia Law
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Criminal Law