Justia Arkansas Supreme Court Opinion Summaries

Petitioner filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The circuit court denied the petition. Petitioner subsequently filed a motion for modification of the order denying relief. Petitioner then filed the instant petition seeking a writ compelling the circuit judge to act on the motion for modification of order and other relief. The circuit judge subsequently filed a response to the petition and attached a copy of his order disposing of the motion. The Supreme Court held (1) the petition is rendered moot because the judge acted on the motion that was the subject of the mandamus action; and (2) Petitioner’s additional requests are denied.View "Mazurek v. Piazza" on Justia Law

Petitioner was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the judgment. Petitioner subsequently filed several petitions requesting the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. This opinion concerned Petitioner’s fifth such petition, in which Petitioner made an additional request to recall the mandate. Petition also filed a motion to expand the page limitations. The Supreme Court denied Petitioner’s petition to reinvest jurisdiction and recall the mandate and declared moot his motion to expand the page limit, holding (1) Petitioner failed to demonstrate a meritorious claim to present in the proposed petition for writ of error coram nobis and failed to establish a basis for the Court to recall the mandate; and (2) Petitioner’s motion to exceed the page limit was moot because his petition was filed by the clerk with the pages that Petitioner would add.View "Jackson v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder for the death of his twenty-three-month-old son. Appellant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed the appeal and denied and mooted the motions pertaining to the appeal, holding that the trial court did not clearly err in holding that counsel’s performance was not ineffective.View "Ingram v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and aggravated robbery and was sentenced to an aggregate term of life imprisonment without parole. Appellant later filed a pro se petition for writ of habeas corpus, bringing claims pertaining to double jeopardy, sufficiency of the evidence, ineffective assistance of counsel, and his actual innocence. The circuit court denied the habeas petition. Appellant appealed and also filed a motion for appointment of counsel to represent him on appeal. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion for appointment of counsel, holding that because Appellant did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, the circuit court did not err when it dismissed the petition. View "Gardner v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of attempted first-degree murder, committing a terroristic act, and being a felon in possession of a firearm. Appellant later filed a pro se “Motion for Nunc Pro Tunc Order” asking the trial court to enter a new judgment-and-commitment order. The trial court denied the motion on the grounds that the judgment-and-commitment order already reflected the exact sentence that Appellant’s motion sought to have imposed. The Supreme Court dismissed Appellant’s appeal and declared the motions filed in relation to the appeal moot, holding that it was clear from the record that Appellant could not prevail if the appeal were allowed to go forward.View "Frost v. State" on Justia Law

In 2007, Appellant was found guilty of two counts of possession of a controlled substance with intent to deliver and sentenced as a habitual offender. The court of appeals affirmed. In 2010, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. In 2014, Appellant filed a second Rule 37.1 petition. The trial court dismissed the petition, determining that it was not timely filed. Appellant appealed and filed motions seeking an extension of time to file his brief-in-chief and a copy of the record. The Supreme Court dismissed the appeal and declared the motions moot, holding that the trial court did not have jurisdiction to act on the merits of the Rule 37.1 petition, and therefore, this Court did not have jurisdiction in the matter.View "Ewells v. State" on Justia Law

Appellant was found guilty of rape and sentenced to life imprisonment. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. After a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in declining to grant relief under Rule 37.1 under the circumstances of this case because, while counsel erred in some respects, Appellant did not demonstrate that counsel’s deficient performance so prejudiced Appellant’s defense that he was deprived of a fair trial.View "Chunestudy v. State" on Justia Law

In 2013, Appellant pled guilty to several offenses. Appellant subsequently filed a pro se motion for transcript and a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Appellant's motion for transcript and Rule 37.1 petition were filed as two separate pleadings. Appellant’s signature on the Rule 37.1 petition was not notarized, but his signature on the motion for transcript was notarized, and the motion contained a verification that the facts stated in the motion were true and accurate. The circuit court dismissed the Rule 37.1 petition for failure to comply with Rule 37.1(c). The Supreme Court reversed, holding that Appellant’s Rule 37.1 petition was compliant with Rule 37.1(c) under the facts of this case. Remanded.View "Adkins v. State" on Justia Law

Appellant entered a negotiated plea of guilty to a charge of theft of property and received a sentence of a term of imprisonment and sixty months’ probation. Appellant later violated the terms of his probation, and the trial court revoked Appellant’s probation. Appellant subsequently filed a petition to correct an illegal sentence, alleging that his sentence on revocation was illegal. The trial court denied the petition. Appellant appealed, arguing that the adjudication of the State’s petition to revoke was barred by the prohibition against double jeopardy because he had already been incarcerated under an Act 570 Jail Letter signed by his probation officer. The Supreme Court affirmed, holding that Appellant failed to allege an adequate basis for multiple criminal punishments in violation of the prohibition against double jeopardy.View "Thurmond v. State" on Justia Law

Petitioner, an inmate, filed a petition seeking to proceed in forma pauperis, stating that he wished to proceed as an indigent with a petition for declaratory judgment in a civil matter against the Director of the Arkansas Department of Correction. The circuit court denied the petition, concluding that the proposed pleading did not state a colorable cause of action. The Supreme Court denied the motion, holding that Petitioner failed to establish a colorable cause of action that was legitimate and may reasonably be asserted given the facts presented and the current law or a reasonable extension of it.View "Stanley v. Coomer" on Justia Law