Justia Arkansas Supreme Court Opinion Summaries

In two criminal cases, Appellant pleaded guilty to four counts of second-degree forgery and to two counts of second-degree forgery in the Hot Spring County Circuit Court. Appellant subsequently filed a pro se petition for writ of habeas corpus alleging that the trial court lacked jurisdiction to convict and sentence him because he had cashed the forged checks at issue in Garland County rather than in Hot Spring County. The circuit court denied the petition, concluding that Appellant was in possession of the checks in Hot Spring County, which was sufficient to confer jurisdiction on the trial court. On appeal, Appellant alleged that he was not in possession of the forged checks in Hot Spring County. The Supreme Court affirmed, holding that Appellant failed to make a showing of probable cause to believe that some part of the offense was not committed in Hot Spring County.View "Watkins v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery and commercial burglary and sentenced to an aggregate term of 240 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance and that the evidence was insufficient to sustain the convictions. The trial court denied the petition. The Supreme Court dismissed the appeal and mooted the motion Appellant filed in relation to the appeal, holding that the trial court did not clearly err in concluding that trial counsel’s performance was not ineffective. View "Thomas v. State" on Justia Law

In 1994, Appellant was found guilty of rape, kidnapping, and burglary. In 2009, Appellant pleaded guilty to first-degree battery, theft of property, and fleeing. In 2012, Appellant filed a pro se petition for declaratory judgment and for writ of mandamus seeking to challenge the calculation of his parole-eligibility date by the Arkansas Department of Correction (ADC). The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to raise a justiciable issue within the purview of a declaratory-judgment proceeding and failed to establish that there was a cause on which a petition for a writ of mandamus could be granted.View "Smith v. Hobbs" on Justia Law

Appellant entered a negotiated plea of guilty to first-degree murder and possession of firearms by a certain person and was sentenced as a habitual offender to an aggregate term of 420 months’ imprisonment. Appellant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court denied relief without a hearing. The Supreme Court dismissed the appeal and mooted the motion filed in relation to the appeal, holding that Appellant failed to meet his burden of proving prejudice from any deficient performance on the part of trial counsel.View "Robinson v. State" on Justia Law

In 2007, Petitioner was found guilty of two counts of aggravated robbery, two counts of theft of property, and one count of second-degree battery and was sentenced to an aggregate term of 660 months. Petitioner here 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. The Supreme Court denied the petition, holding (1) Petitioner’s claims of ineffective assistance of counsel and trial error were not within the purview of a coram-nobis proceeding; and (2) Petitioner’s claim of a Brady violation was without merit.View "Mason v. State" on Justia Law

After a bench trial, Appellant was found guilty of attempted capital murder, possession of a firearm by a felon, and first-degree battery. Appellant was sentenced to an aggregate term of 120 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, contending that his trial counsel was ineffective in several ways. The trial court denied Appellant’s petition. The Supreme Court affirmed the circuit court’s order, holding that there were no grounds on which to reverse the circuit court’s ruling.View "Green v. State" on Justia Law

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC), filed a complaint against current or former members of the ADC, alleging violations of his civil rights, “failure to protect,” and assault, battery, and negligence. The circuit court dismissed Appellant’s complaint with prejudice, concluding that Appellant’s claims were barred by the doctrine of sovereign immunity and statutory immunity. The Supreme Court affirmed in part and reversed and remanded in part, holding that the circuit court (1) did not err in granting summary judgment to Appellees on Appellant’s claim under 42 U.S.C. 1983 against them in their official capacities in light of Appellant’s request for declaratory and injunctive relief; (2) erred in granting summary judgment to Appellees on Appellant’s failure-to-protect claim under 42 U.S.C. 1983 against Appellees in their individual capacities; and (3) did not err in granting Appellees summary judgment on Appellant’s negligence claim brought against Appellees in their individual capacities.View "Early v. Crockett" on Justia Law

After a jury trial, Appellant was found guilty of several drug-related charges. Appellant was sentenced to an aggregate term of 708 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus challenging the validity of two of his convictions and sentences. Specifically, Appellant argued that his convictions and sentences for the charges of possession of methamphetamine and manufacturing methamphetamine violated the constitutional prohibition against double jeopardy because one offense was a lesser-included offense of the other. The Supreme Court affirmed, holding that Appellant’s double jeopardy rights were not violated in this case because his convictions for the two charges did not arise from the same conduct.View "Bryant v. Hobbs" on Justia Law

Defendant was charged with sexual assault in the third degree and sexual assault in the fourth degree for engaging in sexual intercourse and having sexual contact with an inmate while Defendant was employed at the Arkansas Department of Correction. Defendant filed a motion to suppress, arguing that statements he had made in a recorded interview as part of the application process to be a state trooper had been made involuntarily and without his having been advised of his Miranda rights. The circuit court granted Defendant’s motion. The State brought an interlocutory appeal. The Supreme Court dismissed the interlocutory appeal because the correct and uniform administration of justice was not at issue.View "State v. Wright" on Justia Law

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC), filed a petition for judicial review to challenge a disciplinary action against him by the ADC. The ADC moved to dismiss the petition on grounds of untimeliness. In response, Appellant filed a motion to strike the motion to dismiss and filed a motion for default judgment based on the ADC’s failure to file a responsive pleading. The circuit court granted the ADC’s motion to dismiss and denied Appellant’s motions to strike and for default judgment. The Supreme Court affirmed the order dismissing the petition and denying Appellant’s motions, concluding that the circuit court did not err in its judgment.View "Smith v. Hobbs" on Justia Law