Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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In 1982, Appellant pled guilty to three counts of aggravated robbery and two counts of rape. In 2013, Appellant filed a second petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that the judgment rendered in 1982 was a nullity because the trial court did not have jurisdiction to enter the judgment. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted his motion to supplement the record on appeal, holding the trial court did not err in dismissing the petition, as neither of the claims advanced by Appellant in his petition was sufficient to establish that the judgment of conviction was void on the ground that the trial court lacked jurisdiction. View "Ford v. State" on Justia Law

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Appellant filed in the circuit court a pro se complaint against the Director of the Arkansas Department of Correction (ADC), asserting that, under the Interstate Corrections Compact, he was entitled to be transferred to a prison in California where his family lived. The circuit court dismissed the complaint. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in relation to the appeal, holding that the circuit court did not err in dismissing the complaint, as (1) under the Compact, ADC officials had sole control over whether Appellant would be transferred to another state; and (2) the Director had sovereign immunity. View "Dubois v. Hobbs" on Justia Law

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Appellant filed a pro se petition for judicial review pursuant to Ark. Code Ann. 25-12-212 of the Administrative Procedure Act, asserting that the chairman of the Arkansas Parole Board had improperly denied him release on parole. The circuit court dismissed the petition. The Supreme Court dismissed Appellant’s appeal and mooted his motions related to the appeal, holding that the circuit court did not err in dismissing the petition for judicial review where the petition was untimely filed, failed to state a valid claim of a due process violation, and was barred by sovereign immunity. View "Crossno v. Felts" on Justia Law

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In 2005, Appellant was found guilty of second-degree stalking, first-degree terroristic threatening, and misdemeanor violation of a protective order. In 2007, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The Supreme Court reversed and remanded. On remand, Appellant filed a pro se amended petition for postconviction relief. The trial court denied relief. The Supreme Court dismissed Appellant’s appeal and declared moot Appellant’s motion for rule on clerk because the amended petition was not in compliance with Rule 37.1 because it was not verified in accordance with Rule 37.1(c). View "Branning v. State" on Justia Law

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After a jury trial, Appellant was convicted of two counts of capital murder and sentenced to death. After the Supreme Court affirmed the conviction and sentence, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, asserting twenty-three allegations of ineffective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant’s petition, as Appellant did not receive ineffective assistance of counsel in either the guilt phase or sentencing phase of his trial. View "Wertz v. State" on Justia Law

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After a jury trial, Petitioner was found guilty of two counts of rape for engaging in sexual intercourse with two girls under the age of fourteen. The judgment was affirmed on appeal. After Petitioner unsuccessfully sought postconviction relief pursuant to Ark. R. Crim. P. 37.1, Petitioner filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging claims pertaining to inconsistent statements made by the victims. The petition was denied. Petitioner then filed this second coram-nobis petition, repeating the claims for relief alleged in the first petition. The Supreme Court denied relief, holding that, as with the original petition, Petitioner failed to state a ground for the writ to issue. View "Smith v. State" on Justia Law

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After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment. The Supreme Court affirmed. Appellant sought relief in coram-nobis proceedings and in a habeas-corpus proceeding, without success. Appellant later filed this instant habeas-corpus proceeding, contending that the original judgment-and-commitment order was void and that the trial court did not have the authority after trial to amend the judgment-and-commitment order. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition where Appellant failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Rayford v. Hobbs" on Justia Law

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After a jury trial, Petitioner was found guilty of the rape of a four-year-old girl and sentenced to 360 months’ imprisonment. The Supreme court affirmed. Petitioner later filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecution violated Brady v. Maryland by not giving more advance notice of the child victim’s medical reports pertaining to her having tested positive for sexually transmitted diseases. The Supreme Court denied the petition, holding that Petitioner failed to raise any claim that would support issuance of the writ. View "Lamar v. State" on Justia Law

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Appellant was convicted of two counts of rape and sentenced to two consecutive life sentences. The Supreme Court affirmed, holding (1) the circuit court did not err by denying Appellant’s motion for directed verdict on the rape charges, as substantial evidence supported Defendant’s convictions; (2) the circuit court did not abuse its discretion in conducting voir dire, and the jury was instructed with a correct statement of the State’s burden; and (3) the circuit court did not err by admitting the testimony of Appellant’s grandson, niece, and nephew regarding their allegations of Appellant’s prior sexual acts with them pursuant to the pedophile exception to Ark. R. Evid. 404(b). View "Jeffries v. State" on Justia Law

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After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, alleging that he was entitled to DNA, blood-type, and ballistic testing of items discovered during the investigation of the crime and introduced into evidence at trial. The trial court denied the petition. The Supreme Court affirmed the trial court’s denial of Appellant’s petition, as Appellant failed to rebut the presumption against timeliness, and none of the other claims raised by Appellant were grounds for relief under Act 1780. View "Ferrell v. State" on Justia Law