Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The judgment was affirmed on appeal. Appellant subsequently filed an amended pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was not afforded effective assistance of counsel at trial. After an evidentiary hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the claims raised by Appellant were largely devoid of the factual support required for a finding of ineffective assistance of counsel, and therefore, the trial court did not err in denying relief under Rule 37.1. View "Jones v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. Petitioner later filed a habeas petition seeking scientific testing of certain evidence. On April 11, 2013, the circuit court entered an order denying the petition. Petitioner filed a motion for reconsideration, which was denied. Thereafter, Petitioner filed a notice of appeal from the April 11, 2013 order and a “second notice of appeal” from the denial of his motion for reconsideration. After the second notice of appeal was deemed filed, the record was tendered to the Supreme Court’s clerk, and the clerk declined to lodge it. Petitioner then filed a pro se petition for belated appeal and an amended petition for belated appeal seeking to lodge the record and proceed belatedly with his appeal of the two orders. The Supreme Court treated the petitions as a motion for rule on clerk and denied it, as Petitioner could not succeed on appeal as to either order. View "Clemons v. State" on Justia Law

Appellant was convicted of murder in the first degree and other crimes and was sentenced as a habitual offender to a total term of life imprisonment. After a notice of appeal was filed the Supreme Court granted Appellant’s trial counsel’s motion to be relieved and appointed Patrick Benca to represent Appellant on appeal. As a result of Benca’s noncompliance with an order of the Court and his failure to file an adequate brief on behalf of Appellant, the Supreme Court relieved Benca of his duties as counsel for Appellant, referred Benca to the Committee on Professional Misconduct, and appointed Rosalyn Watts to serve as Appellant’s new attorney in pursuit of his appeal. View "Thompson v. State" on Justia Law

After a jury trial, Appellant was found guilty of eleven counts of rape and one charge of interference with custody. The charges stemmed from Appellant’s conduct with two female minors. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) any error in the circuit court’s decision to deny Appellant’s request to question one of the victims concerning her belief that Appellant was responsible for the arrest of another person was harmless; and (2) Appellant’s argument that the circuit court erred by sustaining the State’s hearsay objection to Appellant’s testimony concerning a conversation he overheard between the other victim and another child was not preserved for appeal. View "Pigg v. State" on Justia Law

Appellant entered a negotiated plea of guilty to one count of first-degree murder and four counts of aggravated robbery. Appellant was sentenced to life imprisonment for each of the charges. The sentencing orders in Appellant’s case referred to Appellant’s parole eligibility after serving one-third of his life sentences. However, parole eligbility was not authorized by the statute in effect at the time the crimes were committed. Appellant filed a petition for writ of habeas corpus, which was denied. On reconsideration, the Supreme Court granted the writ, holding that the sentencing orders entered against Appellant were facially invalid because the circuit court exceeded its authority in sentencing Appellant to life imprisonment with the possibility of parole. Remanded for resentencing. View "Pennington v. Hobbs" on Justia Law

After a jury trial, Defendant was convicted of one count of delivery of cocaine. Defendant was sentenced as a habitual offender to 480 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the circuit court did not err in denying the petition without a hearing; and (2) based on the standard established in Strickland v. Washington, the circuit court did not err in finding that counsel’s performance was not constitutionally defective. View "Nalls v. State" on Justia Law

In 2005, Appellant pleaded guilty to the sale or delivery of a controlled substance. Appellant was sentenced to a term of imprisonment and an additional suspended sentence. In 2012, Appellant pleaded guilty to having violated the terms of the suspended sentence and also entered guilty pleas to crimes entered in a separate case. Appellant was sentenced to a term of imprisonment and to a suspended sentence. In 2014, Appellant filed a petition pursuant to Ark. Code Ann. 16-90-111 to correct the sentence imposed in 2012 on revocation of the suspended 2005 sentence, alleging, inter alia, that the evidence was not sufficient to sustain the judgment of conviction. The trial court denied the petition. The Supreme Court dismissed the appeal, holding that the petition was not timely filed, and therefore, the trial court and appellate court lacked jurisdiction to grant the relief sought. View "McClanton v. State" on Justia Law

After a jury trial, Petitioner was found guilty of attempted rape and two counts of sexual assault in the second degree. The convictions were affirmed on appeal. Petitioner later filed a pro se petition for postconviction relief, which the circuit court denied as untimely. Petitioner did not appeal, but rather, sought leave to proceed with a belated appeal, contending that his underlying petition was not timely filed because he did not receive a copy of the mandate. The Supreme Court denied Petitioner’s motion for belated appeal on the basis that Petitioner did not show good cause for his failure to timely file a notice of appeal. View "Bean v. State" on Justia Law

Appellant was convicted of manufacture of a controlled substance, simultaneous possession of drugs and firearms, possession of a controlled substance with intent to deliver, and possession of drug paraphernalia. Appellant later filed in the Hot Spring County Circuit Court, the county in which he was incarcerated, a pro se petition for writ of habeas corpus. The circuit court dismissed the petition on the merits. Appellant appealed. The Supreme Court dismissed the appeal, as the Hot Spring County Circuit Court could no longer grant the relief requested by Appellant because Appellant was no longer incarcerated in a facility within that county. View "Tyson v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery and theft of property. The total sentence imposed was life imprisonment. On appeal, Appellant argued that the trial court erred in denying his directed-verdict motions challenging the sufficiency of the evidence to support the aggravated robbery and theft-of-property charges. Specifically, Appellant contended, among other things, that the identification evidence was “shaky" and that there was no proof that he was involved in the crimes. The Supreme Court affirmed, holding that the evidence was sufficient to support the convictions, and therefore, the circuit court did not err in denying Appellant’s directed-verdict motions. View "Turner v. State" on Justia Law