Justia Arkansas Supreme Court Opinion Summaries

Appellant was charged with the capital murder of his two-year-old stepdaughter. After jury selection for Appellant’s trial began, the parties reached a plea agreement under which Appellant agreed to plead guilty to first-degree murder and be sentenced by the as yet unsworn jury. After a sentencing trial, the jury sentenced Appellant to life imprisonment. Appellant appealed his sentence, arguing that the circuit court erred in denying his request to conduct additional voir dire of the selected but unsworn jury after the plea agreement had been consummated. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion or violate Appellant’s rights to due process and an impartial jury in refusing to allow additional proffered voir dire.View "Pedraza v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to death. The Supreme Court affirmed the conviction and sentence on appeal. Appellant then sought post-trial relief through a petition for postconviction relief and two habeas corpus petitions, all of which were unsuccessful. Appellant filed the instant motion to recall his direct-appeal mandate just a few weeks after the court of appeals had affirmed the denial of his second habeas petition, asserting that there were two instances of a breakdown in the appellate process that he argued would justify recalling the mandate. The Supreme Court denied the motion, holding that none of Appellant’s arguments demonstrated extraordinary circumstances to justify recalling the mandate in his direct appeal. View "Nooner v. State" on Justia Law

After a jury trial in 2002, Petitioner was found guilty of capital murder and sentenced to death. In 2014, the Supreme Court reversed and remanded for a new trial, concluding that the circuit court had erred in finding that Petitioner had been competent to stand trial. The circuit court subsequently committed Petitioner to the department of human services for detention, care, and treatment until restoration of fitness. Petitioner then filed the present petition for writ of certiorari to challenge the circuit court’s decision to commit him to the department. Petitioner was subsequently transferred to the county jail. Therefore, the Supreme Court granted Petitioner’s motion to dismiss the petition as moot.View "Newman v. Crawford County Circuit Court" on Justia Law

After a jury trial, Appellant was convicted of premeditated and deliberate capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in refusing to allow defense counsel to impeach a State witness with his prior acts of untruthfulness; (2) the circuit court did not abuse its discretion when it prevented Appellant from impeaching the sole eyewitness with his prior inconsistent statements; (3) the circuit court did not err in denying Appellant’s motion for mistrial based on discovery violations; (4) the overlap of the capital murder and first-degree murder statutes does not violate the Arkansas Constitution; (5) the circuit court’s statements revealing irritation of defense counsel’s tactics did not warrant reversal; and (6) Appellant’s argument that the circuit court abused its discretion in failing to conduct a Daubert hearing before admitting expert testimony about a palm print found at the scene of the murder and identified as Appellant’s was precluded from review. View "Maiden v. State" on Justia Law

Appellant filed a petition for writ of habeas corpus in the Crawford County Circuit Court. At the time he filed the petition, Appellant was in the custody of the Arkansas Department of Correction at the Ouachita River Unit in Hot Spring Unit and remained in custody at that unit. The circuit court denied the petition. Appellant appealed. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the Crawford County Circuit Court did not have personal jurisdiction to issue and make returnable a writ of habeas corpus for Appellant in Hot Spring County.View "Jones v. State" on Justia Law

William James, an attorney, represented Joshua Hastings in a manslaughter trial. During the trial, the presiding judge found James of ten contempt violations. The trial ended in a mistrial. James subsequently filed a motion to vacate the contempt findings, which was denied. The Supreme Court reversed and dismissed nine of the ten citations, each of which was rendered at the close of trial after the circuit court had declared a mistrial, holding (1) the circuit court denied James notice and a reasonable time to make his defense in violation of Arkansas law; and (2) substantial evidence did not support the circuit court’s finding of contempt.View "James v. Pulaski County Circuit Court Fifth Div." on Justia Law

After a jury trial, Appellant was found guilty of the lesser-included offense of second-degree murder and sentenced to a total of 780 months’ imprisonment, plus a $15,000 fine. On appeal, Appellant argued that the instructions given to the jury inaccurately stated the law because they failed to instruct the jury that the State was required to prove that the murder was not manslaughter in accordance with Fincham v. State. The Supreme Court affirmed Appellant’s conviction and sentence, holding that the Court was precluded from addressing Appellant’s argument, as it was raised for the first time on appeal.View "Hampton v. State" on Justia Law

In 2006, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. In 2010, Appellant sent two letters to Thomas Deen, the prosecuting attorney, requesting that he permit the custodian of records for the crime lab to release, pursuant to the Arkansas Freedom of Information Act, documentation of testing performed on hairs recovered from the body of the victim in his criminal case. The prosecuting attorney did not respond. In 2012, Appellant filed a petition for writ of mandamus against Deen requesting an order directing Deen to give the crime lab permission to release the information. The circuit court dismissed the petition, concluding that Appellant had no legal right to the requested information. The Supreme Court reversed, holding that a defendant has a right to access all records pertaining to his criminal case and that the crime laboratory is required to disclose to a defendant all evidence in the defendant’s case that is retained by the laboratory.View "Davis v. Deen" on Justia Law

Appellant, an inmate at the Arkansas Department of Corrections (ADC), filed a pro se petition for declaratory judgment and for writ of mandamus challenging the calculation of his parole-eligibility date by the ADC. Specifically, Appellant argued that the application of Act 1805 of 2001 to his sentence amounted to an enhancement of the sentence and that the Act removed an inmate’s ability to be eligible for parole contrary to the dictates of Act 536 of 1993 and Act 558 if 1883. The circuit court denied and dismissed the petition with prejudice. The Supreme Court affirmed, holding that Appellant did not establish that there was a justiciable issue that merited relief in a declaratory judgment proceeding or that there was a cause on which a petition for writ of mandamus could be granted.View "Brown v. Hobbs" on Justia Law

Appellant pleaded guilty to violating the terms of his previously imposed probation and was sentenced to a term of ninety-six months’ imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus, contending that his probation was revoked in an untimely proceeding, his counsel provided ineffective assistance in the revocation proceeding, his speedy trial rights were violated, and the trial court did not follow proper procedure in accepting his plea. The circuit court dismissed the petition, concluding that Appellant failed to state a ground on which a writ of habeas corpus could issue. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the petition, as the petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction.View "Wesson v. Hobbs" on Justia Law