Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Slocum v. State
Petitioner was found guilty of capital murder and sentenced to life imprisonment without parole. In his pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, Petitioner contended that he was entitled to issuance of the writ on the ground that the State wrongfully withheld material evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that Petitioner failed to meet his burden of showing that the State withheld information that would have resulted in a different outcome in the proceedings.View "Slocum v. State" on Justia Law
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Criminal Law
Sales v. State
Appellant was convicted of capital murder and aggravated robbery. Appellant was sentenced to death and life imprisonment, respectively. The Supreme Court affirmed on appeal. Appellant then filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, alleging that his trial counsel were ineffective during the sentencing phase of his capital-murder trial and during opening statements. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court correctly concluded that Appellant was not entitled to relief because he could not demonstrate that he was prejudiced as required by the second prong of Strickland v. Washington at either phase of his trial.View "Sales v. State" on Justia Law
Quezada v. Hobbs
Appellant pleaded guilty to one count of delivery of a controlled substance and two counts of possession of a controlled substance with intent to deliver. Appellant was sentenced to a total of 300 months’ imprisonment with an additional 180 months’ suspended imposition of sentence for each count. Appellant later filed a pro se petition for writ of habeas corpus, claiming that the proscription against double jeopardy was violated in his case because he was convicted of both delivery of a controlled substance and possession of the controlled substance with intent to deliver. The circuit court denied habeas relief. The Supreme Court affirmed, holding that Appellant did not meet his burden of demonstrating that the face of the judgment demonstrated that the judgment was invalid.View "Quezada v. Hobbs" on Justia Law
Harmon v. State
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
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Criminal Law
Decay v. State
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
Chatmon v. State
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
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Criminal Law
Chance v. Hobbs
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
Carroll v. Hobbs
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
Atkins v. State
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
Schrader v. State
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