Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Petitioner was found guilty of aggravated robbery and sentenced to 240 months’ imprisonment. The court of appeals affirmed. Petitioner filed a pro se petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he may proceed with a petition for writ of error coram nobis, contending that the prosecution withheld evidence from the jury that was contained in the probable cause affidavit. The Supreme Court denied the petition, holding that Petitioner failed to establish a Brady violation with respect to the probable cause affidavit. View "Chestang v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of raping his seven-year-old stepdaughter. After the mandate issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging, among other claims, ineffective assistance of counsel. The trial court dismissed the petition after a hearing. The Supreme Court affirmed, holding (1) the trial court did not clearly err in holding that counsel’s performance was not ineffective; (2) the trial court correctly held that Appellant’s claim of prosecutorial misconduct at trial was not cognizable in a Rule 37.1 proceeding; and (3) Appellant’s claim that he was dissatisfied with his attorney’s representation in the Rule 37.1 proceeding was not grounds to reverse the trial court’s order and remand for a new hearing. View "McNichols v. State" on Justia Law

After a jury trial, Petitioner was found guilty of capital murder and battery in the first degree. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, which the trial court denied. The Supreme Court dismissed the appeal. Petitioner then filed a request that the Supreme Court reinvest jurisdiction in the trial court so that he may proceed with a petition for writ of error coram nobis. Petitioner also sought an injunction arising out of the coram-nobis proceeding. The Supreme Court denied the petition and declared the request for an injunction moot, holding that Petitioner failed to state a cause to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, and thus the request for an injunction was moot. View "Grant v. State" on Justia Law

After a jury trial in 1988, Appellant was convicted of capital murder. Appellant was sentenced to life imprisonment without parole on the murder charge. In 2012, Appellant filed a pro se petition for writ of habeas corpus. The circuit court denied the petition, and the Supreme Court affirmed. In 2013, Appellant tendered another pro se petition for writ of habeas corpus in which he requested that he be permitted to proceed in forma pauperis in the habeas proceeding. The circuit court denied the petition on the merits and denied leave to proceed in forma pauperis. The Supreme Court affirmed, holding that Appellant’s claims were not within the purview of a habeas proceeding. View "Davis v. State" on Justia Law

In 2013, the State field a petition pursuant to the State Prison Inmate Care and Custody Reimbursement Act seeking funds held in Appellant’s inmate account as reimbursement for a portion of the cost of housing Appellant in the Arkansas Department of Correction. The circuit court found that the State had proven its claim to reimbursement and ordered that $6140.42 held in Appellant’s inmate account be deposited in the Arkansas State Treasury. The Supreme Court affirmed the order, holding that the arguments Appellant raised on appeal were either waived, without merit, or unreviewable on appeal. View "Barker v. State" on Justia Law

Appellant, an inmate of the Arkansas Department of Correction, was found guilty of capital murder in the stabbing death of a fellow inmate. Appellant filed a pro se petition for writ of habeas corpus, arguing that the trial court made several errors in its rulings on defense motions during voir dire and during trial and that his counsel provided ineffective assistance. The circuit court dismissed the petition, noting that the action counted as a “strike” pursuant to Ark. Code Ann. 16-68-607. The Supreme Court affirmed, holding (1) Appellant did not show that the court failed to address any issue cognizable in a habeas proceeding; (2) Appellant’s claims of trial error and ineffective assistance of counsel were not within the purview of a habeas proceeding; and (3) inasmuch as Appellant’s petition for writ of habeas corpus failed to state a claim on which relief was merited, the circuit court did not err in declaring that the petition constituted a strike under the statute. View "Tucker v. Hobbs" on Justia Law

Defendant was charged with drug and firearm offenses. Defendant filed a motion to suppress the items discovered during a search of his person and his minivan. The circuit court granted the motion after a hearing. The State appealed, arguing that the circuit court erred as a matter of law (1) by concluding that additional officer testimony was required to support the pat down of Defendant, and (2) when it found that a warrant was required to search a locked safe discovered in Defendant’s minivan. The Supreme Court dismissed the appeal in part and reversed and remanded in part, holding (1) the State’s first point on appeal is not appealable because it involves the circuit court’s consideration of the particular facts of the case and its determination that those facts did not justify the search of Defendant’s person; and (2) the circuit court erred as a matter of law in finding that, absent exigent circumstances, a warrant was required to search the safe in Defendant’s minivan. View "State v. Crane" on Justia Law

After a jury trial, Appellant was convicted of kidnapping. Appellant was sentenced to life imprisonment. Appellant filed a motion for new trial based on juror misconduct, alleging that a certain juror had used her cell phone to post on a social media website during jury deliberation in violation of the circuit court’s instructions not to do so. After a hearing, the circuit court granted Appellant’s motion for new trial, concluding that by posting to Facebook, the juror had disregarded and violated the court’s clear orders and that, as a result, Appellant had not received a fair trial. The Supreme Court dismissed the State’s appeal, holding that the Court did not have jurisdiction over the appeal, as it turned on whether the circuit court’s findings were supported by the unique facts in this case and did not involve the correct and uniform administration of the law. View "State v. Riley" on Justia Law

After a jury trial, Petitioner was found guilty of rape of a person less than fourteen years old and two counts of sexual assault in the first degree. Petitioner was sentenced to life imprisonment on the rape charge. Now before the Supreme Court was Petitioner’s pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, in which Petitioner asserted that material evidence was withheld from him in violation of Brady v. Maryland. Because Petitioner’s petition was actually one of ineffective assistance of counsel, the Supreme Court denied relief, as claims of ineffective assistance of counsel are not cognizable in error-coram-nobis proceedings. View "Ratchford v. State" on Justia Law

After a jury trial, Petitioner was found guilty of first-degree murder and sentenced to 420 months’ imprisonment. The court of appeals affirmed. Petitioner later filed a pro se petition seeking to reinvest jurisdiction in the circuit court to consider a petition for writ of error corm nobis and subsequently filed an amendment to the petition. In her petition, Petitioner asserted that coram-nobis relief was warranted because Brady v. Maryland was violated, the trial judge was biased, the Arkansas Rules of Evidence were violated, and she was not competent to stand trial. The Supreme Court denied the petition as amended, holding that Petitioner failed to raise any claim that would support issuance of a writ of error coram nobis. View "Mooney v. State" on Justia Law