Justia Arkansas Supreme Court Opinion Summaries

In 1986, Appellant pleaded guilty to rape and kidnapping charges in two separate cases. Appellant was sentenced to life imprisonment for rape in each of the cases. In 2013, Appellant filed a pro se petition for writ of error coram nobis, alleging several claims. The trial court denied the petition on the basis that the claims were conclusory in nature and because Appellant did not act with due diligence in filing the petition. The Supreme Court affirmed, holding that the trial court did not err in finding that the claims in the petition were unsupported by factual substantiation sufficient to warrant a hearing and were not raised with due diligence. View "Weekly v. State" on Justia Law

After a jury trial, Petitioner was found guilty of residential burglary, aggravated robbery, and first-degree battery. The court of appeals affirmed. Petitioner subsequently filed a pro se petition requesting permission to proceed with a petition for writ of error coram nobis, alleging ineffective assistance of counsel. The petition was denied. Petitioner then filed a second petition, which the Supreme Court construed as a request that jurisdiction be reinvested in the trial court so that Petitioner may proceed with a petition for writ of error coram nobis, claiming that he was denied effective assistance of counsel and that the evidence was not sufficient to sustain the judgment-and-commitment order, and requesting that the Court recall the direct-appeal mandate. The Supreme Court denied the petition, holding that Petitioner’s claims were either not cognizable in coram-nobis proceeding or were without merit.View "Washington v. State" on Justia Law

Derrick Thomas was charged with second-degree battery and second-degree assault for an incident at the Arkansas State Hospital, where Thomas had been committed for a mental evaluation in a separate criminal case in which he had been found to be incompetent to stand trial. Thomas moved to dismiss the battery charges, arguing that he was unfit to proceed to trial. The circuit court dismissed the battery charges after a hearing. The State appealed, arguing that the circuit court’s dismissal of the battery charges violated Ark. Code Ann. 5-2-310(c)(2) because there was no requisite finding that Thomas had regained competence to stand trial. The Supreme Court reversed, holding that the circuit court improperly construed section 52-310(c) in concluding it had authority to dismiss the charges against Thomas. Remanded.View "State v. Thomas" on Justia Law

After a jury trial in 1991, Petitioner was found guilty of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed. Petitioner later 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, raising three grounds for the writ. The Supreme Court denied the petition, holding (1) Petitioner failed to establish that the State violated Brady v. Maryland by withholding evidence from the defense; and (2) the remainder of Petitioner’s claims were not cognizable in an error-coram-nobis proceeding. View "McArthur v. State" on Justia Law

In 2009, judgment was entered reflecting that Appellant had entered a negotiated plea of nolo contendere to fourteen felony offenses. In 2012, Appellant filed a pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, alleging that his counsel provided ineffective assistance when he entered the plea. The trial court denied the petition. The Supreme Court affirmed, holding (1) the petition was not timely filed, and accordingly, the trial court had no jurisdiction to grant the relief sought; and (2) even if considered under the provision in the statute that allows the trial court to correct an illegal sentence at any time, Appellant was not entitled to relief.View "Livingston v. State" on Justia Law

Appellant entered a negotiated plea of guilty to the charge of rape and was sentenced to 216 months’ imprisonment with an additional suspended imposition of eighty-four months’ imprisonment. More than one year after the sentencing order had been entered of record, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming ineffective assistance of counsel. The circuit court denied the petition as untimely. Appellant lodged an appeal and filed a pro se motion for extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot because the petition for postconviction relief was not timely filed, and therefore, the trial court had no jurisdiction to grant the relief sought.View "Daniell v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. Petitioner later filed a pro se petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis alleging that the State withheld material evidence from the defense in violation of Brady v. Maryland. The petition was denied. Thereafter, Petitioner filed a second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error nobis, again claiming that the State withheld information that would have resulted in a different outcome in the proceedings. The Supreme Court dismissed the petition, holding that Petitioner did not establish a basis for issuance of the writ in his first petition, and Petitioner’s reassertion of essentially the same claims in the instant petition was a misuse of the remedy.View "Allen v. State" on Justia Law

In 2003, Petitioner was found guilty of the rape of a child. The court of appeals affirmed the conviction and sentence. Petitioner later filed a 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. As grounds for the writ, Petitioner contended that new evidence established that he was actually innocent of the offense. The Supreme Court denied the petition, holding that the grounds for relief advanced by Petitioner did not warrant granting a writ of error coram nobis.View "White v. State" on Justia Law

Petitioner pleaded guilty to aggravated robbery. Thereafter, Petitioner filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel. The petition was denied. Petitioner subsequently filed a “motion of appeal” but did not timely file a notice of appeal that complied with the Rules of Appellate Procedure-Criminal. Petitioner subsequently filed a motion seeking leave to proceed with a belated appeal of the order. The Supreme Court denied the motion, holding that there was no good cause to permit a belated appeal, as Petitioner could not prevail on appeal from the trial court’s order.View "Rowan v. State" on Justia Law

In 1978, Appellant pleaded guilty to first-degree murder, four counts of aggravated robbery, and first-degree battery. Appellant received concurrent sentences of life imprisonment for the charge of murder and each of the aggravated-robbery charges. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging, among other claims, that his sentence to life imprisonment without the possibility of parole for crimes he committed when he was a minor was unconstitutional. The Supreme Court dismissed the appeal and declared moot or denied the motions filed pertaining to the appeal, holding (1) because Appellant was not subjected to a mandatory sentence of life without parole, Appellant’s sentences were not illegal under Miller v. Alabama; and (2) the remaining assertions raised by Appellant were not cognizable in a habeas proceeding.View "Pennington v. Hobbs" on Justia Law