Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of the offense of failure to appear and sentenced to seven years' imprisonment. On appeal, Appellant argued that there was insufficient evidence to support his conviction because he had not yet been charged with a crime when he failed to appear, and therefore, the circuit court erred in denying his motion for a directed verdict. The Supreme Court reversed and dismissed Appellant’s conviction and sentence, holding that the circuit court erred in denying Appellant’s motion for a directed verdict because Appellant could not be convicted of the offense of felony failure to appear when he had not yet been charged with any criminal offense. View "Thompson v. State" on Justia Law

After a jury trial, Appellant was found guilty of the rape of twenty-three-year-old J.H., who was incapable of consent by virtue of her mental age of six or seven years. Appellant was sentenced to 840 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel at trial. The trial court denied the petition after a hearing. The Supreme Court affirmed, holding that Appellant failed to establish that his counsel’s performance was deficient in any respect. View "Stewart v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder, aggravated residential burglary, kidnapping, and rape. Appellant was sentenced to life without parole for the capital murder conviction. On appeal, Appellant argued that the circuit court erred in denying his objection to the State’s use of peremptory challenges in violation of Batson v. Kentucky. Specifically, Appellant claimed that there was purposeful discrimination in that six of the eight strikes used by the State were strikes of black potential jurors, which resulted in Appellant, an African American, being tried by an all-white jury. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Appellant’s Batson challenge. View "McMiller v. State" on Justia Law

In 1994, Appellant was found guilty in two separate cases of capital murder and first-degree murder. Appellant was sentenced to life imprisonment for the capital-murder conviction. In 2012, Appellant filed a pleading that the circuit court treated as a petition for writ of habeas corpus, raising allegations of, inter alia, prosecutorial and police misconduct, due process violations, juror bias, and actual innocence. The circuit court denied relief. The Supreme Court affirmed the circuit court’s order of dismissal, holding that there was no basis for a finding that a writ of habeas corpus should issue. View "Hill v. State" on Justia Law

Petitioner, an inmate, filed a pro se motion to dismiss and vacate a sentence. The circuit court denied the motion. Petitioner subsequently filed a timely notice of appeal and tendered a partial record to the Supreme Court with a motion for belated appeal, asserting that the record was not timely tendered because the circuit court allegedly declined to prepare the record until Petitioner’s status as an indigent person was certified by the court. The Court treated the motion for belated appeal as a motion for rule on clerk and denied the motion, holding that Petitioner failed to establish good cause for the procedural default. View "Hall v. State" on Justia Law

Appellant pleaded guilty to two counts of conspiracy to deliver a controlled substance. The State later conceded that the sentence was illegal on its face inasmuch as the sentence imposed for each of the two offenses exceeded the statutory range. Therefore, the pleas were set aside and the judgment-and-commitment order was vacated. Thereafter, Appellant pleaded guilty to the two charges and was sentenced to 300-month sentence and a 180-month suspended sentence, to be served consecutive to the 300-month sentence. Appellant subsequently filed a pro se motion to correct illegal sentence or reduction of sentence. The trial court denied the relief sought. The Supreme Court affirmed the trial court’s order but modified the suspended sentence to run concurrently with the sentence of 300 months’ imprisonment. View "Gray v. State" on Justia Law

Appellant, by and through his attorney, John Irwin, filed a motion for rule on clerk and a motion to be relieved as counsel. Irwin, a full-time, state-salaried public defender, stated in his motion for rule on clerk that the clerk refused to file the untimely record because of Irwin’s failure to follow the Arkansas Rules of Appellate Procedure-Criminal. The Supreme Court granted the motion for rule on clerk, as Irwin candidly admitted fault for the failure to perfect the appeal, and granted the motion to be relieved as counsel, as Irwin was not eligible for compensation on appeal. View "Childers v. State" on Justia Law

Appellant pleaded guilty to eight counts of aggravated robbery and other crimes. Appellant later filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, contending that there was new scientific evidence that would prove he was actually innocent of seven of the counts of aggravated robbery to which he pled guilty and that he should have been convicted of only one of five aggravated robbery counts because the five robberies were a continuing course of conduct. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was entitled to relief under the Act.View "Barton v. State" on Justia Law

In 1978, Appellant entered negotiated pleas of guilty in circuit court to one count of first-degree murder, four counts of aggravated robbery, and one count of first-degree battery. Appellant received concurrent sentences of life imprisonment for the first-degree murder charge and each of the aggravated-robbery charges. The sentencing orders for each charge stated that Appellant was to serve one-third of the sentences before becoming eligible for parole. In 2013, Appellant filed a pro se petition for writ of habeas corpus, alleging, inter alia, that the sentencing orders were facially invalid and that his life sentences for aggravated robbery and first-degree murder were unconstitutional. The circuit court denied the petition. The Supreme Court reversed and issued a writ of habeas corpus, holding that the sentencing orders entered in this case were facially invalid because the circuit court exceeded its statutory authority by sentencing Defendant to terms of imprisonment of life with the possibility of parole for Class A felonies.View "Hale v. Hobbs" on Justia Law

Petitioner, an inmate incarcerated in the Arkansas Department of Correction, filed a petition seeking a writ of habeas corpus. The circuit court denied the petition for habeas relief. Petitioner failed to file a timely notice of appeal. Petitioner subsequently filed a motion that the Supreme Court treated as a motion to proceed with a belated appeal, asserting that the clerk was at fault concerning his failure to file a timely notice of appeal. The Supreme Court denied the motion, holding that Petitioner did not provide any ground for the motion that had merit, and therefore, Petitioner did not establish good cause for his failure to file a timely notice of appeal.View "Travis v. Hobbs" on Justia Law