Justia Arkansas Supreme Court Opinion Summaries

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

After a jury trial in 2011, Appellant was found guilty of attempted residential burglary and sentenced as a habitual offender to 360 months’ imprisonment. In 2013, Appellant filed a pro se petition for postconviction relief, alleging that his trial counsel was ineffective by failing to investigate the jury pool and learn that two of the prospective jurors were employees of the Arkansas Department of Correction (ADC) and by failing to allow the trial court to admonish the potential jurors regarding the ADC employees as the court had offered to do. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court (1) did not err in denying the petition without holding an evidentiary hearing; and (2) did not clearly err in concluding that counsel’s performance was effective.View "Spratt v. State" on Justia Law

After a jury trial in 2011, Appellant was found guilty of murder in the first degree and possession of a firearm by a felon. The court of appeals affirmed the judgment. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was not afforded effective assistance of counsel at trial because trial counsel employed improvident trial strategy. After a hearing, the trial court declined to grant relief. The Supreme Court affirmed the trial court’s denial of Appellant’s petition, holding that Appellant did not meet his burden of demonstrating that counsel made specific errors that prejudiced the defense.View "Smith v. State" on Justia Law

In 2013, Petitioner filed a pro se petition for writ of habeas corpus, which the circuit court denied. No appeal was taken. Petitioner subsequently sought leave to proceed with a belated appeal, contending that he did not file a timely notice of appeal because he was not promptly notified by the circuit clerk that the circuit court’s order had been entered. The Supreme Court denied the motion, holding that, even if the order was not promptly forwarded to Petitioner, that fact in itself did not constitute good cause for Petitioner’s failure to follow procedure.View "Oliver v. Hobbs" on Justia Law

In 1999, a jury found Petitioner guilty of a residential burglary and rape. Petitioner was sentenced as a habitual offender to an aggregate sentence of 900 months’ imprisonment. The court of appeals 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, claiming that the State withheld favorable evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that Appellant’s vague allegations of withheld evidence were insufficient to meet his burden of demonstrating that the State had specific evidence that would have been sufficient to have prevented rendition of the judgment.View "Noble v. State" on Justia Law

On August 5, 2013, Appellant entered a negotiated plea of guilty to first-degree murder. On November 15, 2013, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court dismissed the petition on the ground that it was not timely filed. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in relation to the appeal, holding that because Appellant did not file his petition within ninety days of the date of entry of judgment, the trial court lacked jurisdiction to grant postconviction relief, and therefore, the Supreme Court also lacked jurisdiction.View "Muldrow v. State" on Justia Law

After a jury trial in 2001, Appellant was found guilty of four counts of aggravated robbery, three counts of misdemeanor theft of property, and one count of felony theft of property. In 2013, Appellant filed a motion under Ark. Code Ann. 16-112-202 seeking fingerprint testing, DNA testing, and further examination of a videotape. Approximately three weeks later, Appellant filed a “motion for a new trial,” requesting that the videotape be tested under Ark. Code Ann. 16-112-208 and again requesting fingerprint and DNA testing. The trial court denied both pleadings on the ground that the two pleadings were successive habeas pleadings and subject to denial under Ark. Code Ann. 16-112-205(d). The Supreme Court affirmed, holding that the trial court did not err in denying the pleadings.View "Hutcherson v. State" on Justia Law