Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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Appellant was convicted of first-degree murder, two counts of aggravated robbery, and aggravated assault. On appeal, Appellant argued that the circuit court abused its discretion in granting the State’s motion to exclude from evidence a portion of DNA results indicating the presence of more than one contributor to the DNA profiles on items of clothing found near the car that the assailant abandoned the night of the crime. According to Appellant, the evidence was highly probative to his defense and would not have been unduly confusing or misleading to the jury. The court of appeals affirmed. The Supreme Court reversed, holding that the circuit court erred in granting the State’s motion in limine to exclude this evidence. Remanded.View "Harmon v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of two counts of capital murder and sentenced to death. The Supreme Court affirmed the convictions and sentence on appeal. Appellant subsequently filed a Rule 37.5 petition for postconviction relief, asserting that he was denied effective assistance of counsel in several respects. The circuit court denied and dismissed Appellant’s petition. The Supreme Court affirmed, holding that Appellant failed to show that his counsel’s performance was deficient under the two-prong standard set forth in Strickland v. Washington, and therefore, the circuit court did not err in denying Appellant’s petition.View "Decay v. State" on Justia Law

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Appellant was convicted on three counts of aggravated robbery and one count of theft of property, including firearm enhancements, and was sentenced as a habitual offender to a total term of imprisonment for life. Appellant appealed, claiming three allegations of error. The Supreme Court remanded the matter to the circuit court to settle and supplement the record and also ordered rebriefing, holding that the merits of the appeal could not be reached because the record was not in compliance with Arkansas Supreme Court Administrative Order No. 4(a), and Appellant’s brief was not in compliance with Arkansas Supreme Court Rule 4-2(a)(5).View "Chatmon v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of rape and incest. Ten years later, Appellant filed a petition for writ of habeas corpus, alleging (1) he never gave permission to “dismiss or waive” a jury trial; (2) Ark. R. Crim. P. 24.3-24.7 were not adhered to; and (3) the public defenders allowed perjured testimony to be entered and not challenged. The circuit court denied the habeas petition. Appellant lodged an appeal of that order and filed a motion for extension of time to file a reply brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Petitioner 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 "Chance v. Hobbs" on Justia Law

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Appellant entered a plea of guilty to rape and was sentenced as a habitual offender to 720 months’ imprisonment. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the Arkansas Department of Correction (ADC), arguing that the Director denied him due process of law by applying Ark. Code Ann. 16-93-611 and 5-4-501(c) to his case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not demonstrate that both the statutory provisions requiring him to be fifty-five years of age and also to have served seventy percent of his sentence should not have been applied to his parole or transfer eligibility, or that he was entitled to any relief by means of a declaratory judgment or writ of mandamus. View "Carroll v. Hobbs" on Justia Law

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After a jury trial, Appellant was found guilty of first-degree battery, being a felon in possession of a firearm, and use of a firearm in commission of a felony. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. Appellant then filed a pro se petition to correct an illegal sentence, raising several allegations of error. The trial court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s claims were either not within the purview of his petition to correct an illegal sentence or without merit.View "Atkins v. State" on Justia Law

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Appellant entered a plea of guilty to three counts of rape and was sentenced to three consecutive terms of life imprisonment. Appellant subsequently filed in the trial court a petition for writ of error coram nobis, arguing that the writ should issue on the ground that he was not afforded effective assistance of counsel with respect to a plea bargain that was offered to him. The trial court denied the petition. The Supreme Court affirmed, holding that the claims in the petition were clearly outside the purview of a coram-nobis proceeding, and therefore, Appellant failed to establish that the writ should issue.View "Schrader v. State" on Justia Law

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Appellant was convicted of two counts of capital murder as well as firearm enhancements. Appellant was sentenced to two life sentences. Appellant appealed, alleging five claims of error. The Supreme Court declined to reach the merits of Appellant’s arguments because Appellant’s brief did not comply with Ark. Sup. Ct. R. 4-2(a)(8)(2014). Specifically, the addendum did not include a DVD introduced by the parties during trial. Further, because there was no evidence of waiver, the case was remanded to the circuit court to settle the record by requiring that a verbatim transcription be made of any audio recording played at trial. Remanded to settle and supplement the record.View "Conte v. State" on Justia Law

Posted in: Criminal Law
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In 2010, Appellant was found guilty of first-degree unlawful discharge of a firearm from a vehicle and sentenced to life imprisonment. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition for postconviction relief did not bear Appellant’s signature accompanied by the verification required by Rule 37.1(c). The petition was denied. The Supreme Court affirmed on the ground that the petition was not verified in accordance with section 37.1(c), and Appellant’s argument that the petition was acceptable without verification was without merit.View "Butler v. State" on Justia Law

Posted in: Criminal Law
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Appellant was found guilty of multiple felony offenses. The court of appeals affirmed. Sixty-two days after the mandate on affirmance of the judgment had been issued, Appellant filed a pro se request for postconviction relief challenging the judgment. The trial court dismissed the petition on the ground that it was untimely. Appellant lodged an appeal from the order and filed a motion for extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot on the basis that the petition before the trial court was not timely filed, and therefore, the trial court lacked jurisdiction to grant the relief sought.View "Andrade-Martinez v. State" on Justia Law

Posted in: Criminal Law