Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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After a jury trial, Appellant was found guilty of aggravated residential burglary, first-degree battery committed in the presence of a child, and having employed a firearm in the aggravated burglary. The court of appeals affirmed. Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. Appellant subsequently filed a motion for an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and mooted the motion, holding that Appellant’s counsel provided constitutionally effective assistance at trial. View "Caery v. State" on Justia Law

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After a jury trial, Appellant was found guilty of attempted second-degree murder, arson, and second-degree domestic battering. Appellant was sentenced to an aggregate term of 564 months’ imprisonment. The court of appeals affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order was void and invalid on its face because the trial court lacked jurisdiction to convict and sentence him on the charges of attempted second-degree murder and second-degree domestic battering. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish the facial invalidity of the judgment or demonstrate that the trial court lacked jurisdiction, and therefore, there was no basis on which a writ of habeas corpus could issue. View "Townsell v. State" on Justia Law

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After a jury trial, Appellant was found guilty of possession of a controlled substance and resisting arrest and was sentenced as a habitual offender to a term of imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel, prosecutorial misconduct, and due process violations. The circuit court denied the petition without a hearing. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s claims of ineffective assistance did not warrant relief because they were either refuted by the record of lacked factual substantiation; and (2) Appellant’s remaining claims were not cognizable in a Rule 37.1 proceeding. View "Rice v. State" on Justia Law

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After a jury trial, Appellant was found guilty of first-degree murder and criminal use of a prohibited weapon. The Supreme Court affirmed. Appellant subsequently filed a request for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in denying relief, where Appellant failed to establish that his counsel was ineffective for failing to call certain witnesses, and the remainder of Appellant’s points on appeal were not preserved for the Court’s review. View "Pollard v. State" on Justia Law

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In 1992, Appellant pleaded guilty to several crimes. An aggregate sentence of life imprisonment was imposed on the judgments. Appellant subsequently filed several pleadings, including petitions for postconviction relief and for writ of habeas corpus, all of which were denied. In 2013, Appellant filed a pro se petition for declaratory judgment, advancing many of the arguments that he had raised in prior pleadings and seeking to collaterally attack the correctness of the rulings on those pleadings and the decisions of the Supreme Court upholding those rulings on appeal. A special judge of the circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition. View "Peterson v. Jefferson County Circuit Court" on Justia Law

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Appellant entered a guilty plea to murder in the first degree, committing a terroristic act, battery in the first degree, and battery in the second degree. An aggregate sentence of 348 months’ imprisonment was imposed. Appellant filed a pro se petition for reduction of sentence, alleging that his sentence was excessive and challenging his plea of guilty. The trial court denied the motion. The Supreme Court dismissed Appellant’s appeal, holding that the trial court was without jurisdiction to modify Appellant’s sentence, and the petition was also without merit if considered as a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. View "Moore v. State" on Justia Law

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After a jury trial in 2004, Appellant was found guilty of attempted rape and kidnapping. Appellant was sentenced to a term of imprisonment. In 2013, Appellant filed a pro se petition for declaratory judgment against the Director of the Arkansas Department of Correction, a prison warden, and members of the parole board, arguing that Defendants wrongfully denied him release from custody or transfer to the Arkansas Community Corrections. The circuit court dismissed the petition. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s cause of action was barred by sovereign immunity; and (2) Appellant failed to state a basis for declaratory judgment. View "Mitchem v. Hobbs" on Justia Law

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On June 22, 2012, a hearing officer found that Appellant, who was incarcerated in the Arkansas Department of Correction (ADC), had violated disciplinary rules. The hearing officer imposed punishment for the violations. Appellant later filed a petition for judicial review under the Administrative Procedure Act (APA), arguing that, when pursuing the disciplinary proceedings against him, the ADC violated a number of his constitutional rights. The circuit court dismissed the petition, concluding that the petition was untimely. Appellant challenged the circuit court’s dismissal of his petition in a motion for reconsideration, which the trial court denied. The Supreme Court dismissed Appellant’s appeal because Appellant was untimely in seeking judicial review under the APA. View "Koontz v. Hobbs" on Justia Law

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After a jury trial in 1995, Appellee was convicted of capital murder and sentenced to mandatory life imprisonment without the possibility of parole. In 2013, Appellee filed a petition for writ of habeas corpus, asserting that his sentence to life imprisonment was illegal pursuant to Miller v. Alabama because he was a juvenile at the time of the offense. The circuit court granted Appellee’s petition and vacated Appellee’s sentence. The State appealed. The Supreme Court reversed, holding that because the circuit court did not make a finding of probable cause before it issued the writ, the case must be remanded for a determination of whether probable cause was shown to issue the writ. View "Hobbs v. Gordon" on Justia Law

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After a jury trial, Defendant was found guilty of capital murder. The conviction resulted in a sentence of life imprisonment without parole. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief, asserting that he had received ineffective assistance of counsel at trial and on direct appeal. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in ruling that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Watson v. State" on Justia Law