Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Hussey v. State
After a jury trial, Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. The Supreme Court affirmed. Sixteen years after the judgment had been entered, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, asserting that he was actually innocent of the murder and seeking DNA testing of blood on an article of clothing. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish good cause for the lengthy delay in filing his petition and that Appellant’s claim of ineffective assistance of counsel was not properly before the Court.View "Hussey v. State" on Justia Law
Girley v. Hobbs
After a jury trial in 1998, Appellant was found guilty of rape and sentenced to 300 months’ imprisonment. The court of appeals affirmed. In 2013, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, contending that there was scientific evidence in the form of DNA testing not available at the time of his trial that could establish his actual innocence. The trial court declined to order the DNA testing requested. The Supreme Court affirmed, holding that Appellant failed to rebut the presumption against timeliness in Ark. Code Ann. 16-112-202(10), and therefore, the trial court did not err in denying postconviction relief.View "Girley v. Hobbs" on Justia Law
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Criminal Law
Darrough v. State
After a jury trial, Appellant was found guilty of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. The court of appeals affirmed. Appellant sought postconviction relief pursuant to Ark. R. Crim. P. 37.1, without success. Thereafter, Appellant, who was incarcerated at a prison facility in Lee County, filed in the Drew County Circuit Court a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, alleging that there was scientific evidence to demonstrate that he was actually innocent of the offenses of which he was convicted and that his sentence was illegal. The trial court denied the petition. Supreme Court dismissed Appellant’s appeal on the basis that the habeas petition was filed in the wrong court.View "Darrough v. State" on Justia Law
Croston v. State
After a jury trial, Appellant was found guilty of aggravated robbery and theft of property. Appellant was sentenced to 180 months’ imprisonment and a fine of $1000. No appeal was taken. Eight years later, Appellant filed a pro se petition for writ of error coram nobis challenging the judgment. The trial court denied the petition. Appellant appealed and asked that the State be required to produce records to support the claims in the State’s brief. The Supreme Court dismissed the appeal and mooted the request, holding that Appellant could not prevail on appeal, as the Court already considered the issues raised in the coram-nobis petition and determined that there were no grounds stated to warrant issuance of the writ.View "Croston v. State" on Justia Law
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Criminal Law
Canada v. State
In 2013, Petitioner entered a plea of guilty to battery in the first degree and endangering the welfare of a minor. Petitioner subsequently filed a motion requesting leave to proceed with a belated appeal from the judgment of conviction. The Supreme Court denied the motion, holding that Petitioner did not meet his burden of establishing that he was entitled to proceed with a belated appeal, as he did not contend that his plea was conditional or that it otherwise met any of the exceptions that would allow for an appeal from the judgment.View "Canada v. State" on Justia Law
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Criminal Law
Brown v. Hobbs
Appellant filed a pro se petition for writ of habeas corpus challenging the validity of a 2009 judgment-and-commitment order filed in the Crittenden County Circuit Court. Specifically, Appellant argued that a time-computation card issued to him by the Arkansas Department of Correction reflected a release date that did not coincide with the terms of his plea agreement. The circuit court dismissed the habeas petition for failure to state a claim. The Supreme Court affirmed, holding that, even assuming that Appellant’s claims were true, such arguments were not cognizable in a petition for writ of habeas corpus.View "Brown v. Hobbs" on Justia Law
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Criminal Law
State v. Rainer
After a jury trial, Appellant was convicted of second-degree murder and sentenced to eighty years in prison. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37 alleging ineffective assistance of counsel. The circuit court granted relief and ordered a new trial, concluding that Appellant’s trial counsel was ineffective for failing to renew a challenge to the circuit court’s decision to exclude evidence of the victim’s prior act of violence, thus depriving Appellant of his opportunity to present a complete defense. The Supreme Court reversed, holding that the circuit court’s initial decision to exclude the evidence was not in error, and therefore, there was no basis on which to grant postconviction relief.View "State v. Rainer" on Justia Law
Smith v. Hobbs
After a jury trial in 1994, Appellant was found guilty of several felonies and sentenced to an aggregate term of forty years in prison. The Supreme Court affirmed. In 2012, Appellant filed a pro se petition for writ of habeas corpus alleging that the circuit court lacked jurisdiction to convict and sentence him because the felony information was filed by the prosecuting attorney rather than on a grand jury indictment. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s claims were without merit and were not cognizable in a habeas-corpus petition.View "Smith v. Hobbs" on Justia Law
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Criminal Law
Sanders v. Straughn
Appellant was convicted on two counts of capital murder and sentenced to life imprisonment. Appellant filed a petition for writ of habeas corpus setting forth a number of allegations or error. The circuit court dismissed the petition on the grounds that Appellant failed to establish probable cause for a writ of habeas corpus to issue. The Supreme Court affirmed, holding (1) Appellant’s arguments concerning the validity of the charging instruments, intertwined with other arguments concerning trial error, failed; and (2) the remainder of Appellant’s arguments were not grounds for issuance of a writ of habeas corpus.
View "Sanders v. Straughn" on Justia Law
Robinson v. State
After a jury trial, Petitioner was found guilty of two counts each of attempted first-degree murder and first-degree battery. The court of appeals affirmed. Petitioner subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that, based on a totality of the evidence, the trial court did not clearly err in denying Petitioner’s petition, as Petitioner did not meet his burden of overcoming the presumption that his trial counsel was effective.View "Robinson v. State" on Justia Law