Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Petitioner was found guilty of delivery of a controlled substance and sentenced as a habitual offender to 480 months’ imprisonment. After the court of appeals affirmed on appeal, Petitioner filed a 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 writ, holding (1) Petitioner’s claims of trial error and complaints that his attorney did not render effective assistance of counsel were not cognizable in a coram-nobis proceeding; and (2) Petitioner’s assertion that the prosecution withheld material evidence was without merit.View "Wilson v. State" on Justia Law

Appellant was charged with capital murder and residential burglary in the stabbing death of his former girlfriend. After a jury trial, Appellant was convicted as charged and sentenced to death for the murder conviction. Appellant filed a petition and amended petition for postconviction relief, arguing that his trial counsel was ineffective for several reasons. Following a hearing, the circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to show that his trial counsel’s performance fell below and objective standard of reasonableness or that his performance so prejudiced Appellant’s defense as to deprive him a fair trial.View "Marcyniuk v. State" on Justia Law

Petitioner was found guilty of rape and first-degree battery. Petitioner later filed a petition 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 did not meet his burden of establishing that the prosecution withheld material evidence in violation of Brady v. Maryland; (2) Petitioner’s ineffective assistance of trial counsel claim was outside the purview of a coram-nobis proceeding; and (3) Petitioner’s claim that he was not afforded an adequate opportunity to present claims of ineffective assistance of counsel in a postconviction petition was not within the scope of a coram-nobis proceeding.View "Jarrett v. State" on Justia Law

In 1982, Appellant pleaded guilty to first-degree murder and was sentenced to life imprisonment. In 2013, Appellant filed a petition for writ of habeas corpus, asserting that his sentence of life imprisonment was illegal because he was a juvenile at the time of the offense and the sentencing court did not consider his youth as required by Miller v. Alabama and Jackson v. Norris. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because Appellant was not mandatorily sentenced to life in prison but to a discretionary sentence Appellant’s sentence was not illegal under Miller or Jackson.View "Brown v. Hobbs" on Justia Law

After a jury trial, Appellant, who was seventeen years old at the time of the crime, was found guilty of first-degree murder and sentenced to life imprisonment. Appellant later filed a pro se petition for writ of habeas corpus, arguing, among other things, that his sentence was illegal because he was sentenced to life in prison for a crime committed while he was a juvenile without any consideration of his youth. The circuit court dismissed the petition. The Supreme Court affirmed, holding (1) because Appellant’s life sentence for first-degree murder was not mandatory, Appellant’s sentence was not illegal under Miller v. Alabama; and (2) Appellant’s claims of ineffective assistance of counsel were not cognizable in a habeas proceeding. View "Bowen v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding (1) the circuit court did not err by refusing to suppress the in-court identification of a witness at the scene of the murder, as, under the circumstances, there was no substantial likelihood of misidentification; and (2) the circuit court did not err by denying Appellant’s motion for mistrial on the grounds of prosecutorial misconduct, as any possible prejudice stemming improper remarks made by the prosecutor during closing argument were cured by the circuit court’s admonition to the jury.View "Williams v. State" on Justia Law

While incarcerated at a prison facility in Lee County, Appellant filed a pro se petition to correct an illegal sentence in the Lee County Circuit Court. The circuit court denied the petition. Appellant filed a “motion for reconsideration,” seeking leave to file a belated reply brief. The Supreme Court dismissed the appeal and mooted the motion because Appellant’s petition to correct his sentence, which was imposed in Nevada County, was filed in the wrong court. Only the trial court in Nevada County had authority to grant the relief sought, and therefore, the Lee County Circuit Court lacked jurisdiction to grant relief.View "Wesley v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of sexual indecency with a minor and two counts of rape. The court of appeals affirmed. Appellant subsequenty filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition was denied on the ground that it was not timely filed. No appeal was taken, and Appellant later sought leave to proceed with a belated appeal. The Supreme Court denied Appellant’s motion for belated appeal, holding that Appellant could not prevail if he were permitted to proceed with an appeal because the Rule 37.1 petition was not timely filed, and therefore, the trial court had no jurisdiction to grant the relief sought. View "Pruitt v. State" on Justia Law

After a jury trial, Appellant was convicted of the lesser-included offense of manslaughter. Appellant’s sentence was enhanced pursuant to two enhancement statutes, and the circuit court entered a sentencing order sentencing Appellant to a total of thirty-five years in prison. Appellant filed a posttrial motion contending that the enhanced sentence was an illegal sentence and should be set aside because his ten-year enhanced sentence for committing manslaughter in the presence of a child was not authorized under Ark. Code Ann. 5-4-702(a). The Supreme Court affirmed as modified, holding that Appellant’s ten-year sentence pursuant to section 5-4-702(a) was illegal because that statute does not authorize an enhanced sentence for the offense of manslaughter. View "Hart v. State" on Justia Law

Appellant and his father were charged with multiple felony offenses. Appellant entered a negotiated guilty plea to reduced charges in exchange for testifying for the State at his father’s trial. At a second trial for Appellant’s father, Appellant refused to testify and, as a result, his plea agreement was revoked. After a trial, Appellant was convicted of the original offenses for which he was charged. The Supreme Court affirmed. Appellant subsequently filed a pro se writ of habeas corpus, contending that the trial court in his case lacked jurisdiction to enter the judgment because the revocation of his plea agreement was illegal. The circuit court denied the habeas petition. The Supreme Court dismissed Appellant’s appeal, holding that Appellant did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue because the allegations raised by Appellant did not call into question the trial court’s jurisdiction. View "Green v. Hobbs" on Justia Law