Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Britton v. State
After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding that the circuit court did not err by (1) failing to stop trial and conduct a competency hearing on its own volition; (2) failing to grant a mistrial after Appellant had an outburst in front of the jury, as the fundamental fairness of the trial was not affected; and (3) requiring Appellant to wear a stun belt, shackles and handcuffs for the remainder of the trial after his outburst in the courtroom, as Appellant’s own conduct brought about the need for restraints, and he was not denied his right to a fair trial. View "Britton v. State" on Justia Law
Anthony v. State
After a jury trial, Appellant was found guilty of aggravated robbery, first-degree battery, forgery, and fraudulent use of a credit card. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming that his counsel provided ineffective assistance. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his ineffective assistance of counsel claims and that the trial court did not err in denying Appellant’s request for a copy of the record at public expense. View "Anthony v. State" on Justia Law
Ussery v. State
Appellant entered a plea of guilty to several felony offenses and was sentenced to serve an aggregate term of 300 months’ imprisonment. More than eight months after the judgment had been entered, Appellant filed a pro se petition to correct or reduce the sentence, alleging that his counsel provided ineffective assistance and that the sentence violated the Eighth Amendment and the Fourteenth Amendment. The Supreme Court dismissed the appeal, holding that the petition was not timely filed because Appellant filed it more than ninety days after the judgment had been entered of record. View "Ussery v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Stiggers v. State
After a jury trial, Appellant was convicted of first-degree murder and first-degree battery. The court of appeals affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his counsel provided ineffective assistance by failing to interview and call certain witnesses. The circuit court denied postconviction relief. The Supreme Court affirmed, holding that the circuit court did not err in denying relief, where Appellant did not provide any support for his conclusory claims that counsel was ineffective and made no showing that counsel committed any specific error that prejudiced the defense.
View "Stiggers v. State" on Justia Law
McDaniels v. State
Appellant was convicted of two counts of rape of his step-granddaughter and sentenced to a term of 480 months. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, claiming that his trial counsel provided ineffective assistance. The Supreme Court affirmed, holding that the circuit court did not clearly err in rejecting without a hearing Appellant’s claim that trial counsel was ineffective for (1) failing to object to defective charging language and jury instruction; and (2) failing to investigate and utilize evidence of a third party’s semen found on the victim’s pants. View "McDaniels v. State" on Justia Law
Edwards v. State
In two cases, Appellant entered a negotiated plea of guilty to possession of a controlled substance with intent to deliver, simultaneous possession of drugs and firearms, and possession of firearms by a felon. Appellant later filed a petition under Act 1780 of 2001 Acts of Arkansas seeking DNA and latent-fingerprint testing of certain evidence, along with other relief. The trial court denied the petition on the grounds that the petition did not state a basis for relief under the Act. The Supreme Court affirmed, holding that Appellant did not establish a basis for relief under the Act, and therefore, the trial court did not err in denying relief. View "Edwards v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Day v. Hobbs
In 2013, Petitioner, who was incarcerated for multiple felony convictions, filed a pro se petition for writ of habeas corpus. The circuit court denied the petition. Petitioner timely filed a notice of appeal but did not tender the record to the Supreme Court as required by Ark. R. App P.-Crim. 4(b). Appellant later filed a motion and amended motion seeking to lodge the record belatedly and proceed with the appeal, claiming, among other things, that he was not informed how to perfect his appeal. The Supreme Court denied the motion and amended motion, holding that Petitioner did not show good cause for failing to timely tender the record on appeal. View "Day v. Hobbs" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Chambliss v. State
After a jury trial, Appellant was found guilty of two counts each of aggravated robbery and theft of property. The charges arose from the aggravated robbery of two different banks, two days apart, and the charges were joined for trial. Appellant was sentenced to an aggregate term of 672 months imprisonment. After the judgment was affirmed, Appellant filed a pro se petition for postconviction relief, which the trial court denied. Appellant later filed a pro se petition for writ of habeas corpus, raising claims of trial error and insufficiency of the evidence. The Supreme Court denied relief because Appellant failed to raise a claim within the purview of a habeas action and thus failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Chambliss v. State" on Justia Law
Thurmond v. State
In 2012, Appellant entered a negotiated plea of guilty to a charge of theft of property and received a sentence of 120 days’ imprisonment in jail and sixty months’ probation. Appellant subsequently filed a timely petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging that his trial counsel was ineffective. The trial court denied the petition. Appellant appealed. Because Appellant was released from jail after filing his appeal, the Supreme Court held that he was no longer entitled to postconviction relief. Moreover, the Court held that even if Appellant’s claims were not moot, the appeal was without merit. View "Thurmond v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
State v. West
In 2012, the State filed a complaint seeking forfeiture of $7550 in United States currency. The complaint named both the $7550 and Patricia West as defendants in the caption. West filed a motion to dismiss the complaint because the State failed to obtain service on her within 120 days of the filing of the complaint pursuant to Ark. R. Civ. P. 4. The circuit court granted West’s motion to dismiss, concluding that because the State knew that West had an interest in the currency, West must be subject personally to the jurisdiction of the court. On appeal, the State asserted that West was not actually a defendant but only an interest holder in the currency, and the inclusion of West as a named defendant in the complaint did not change the substance of the action as an in rem proceeding against the currency. The Supreme Court affirmed, holding that, because the State did not personally serve West, who was listed as a defendant in the caption of the complaint, the circuit court did not err in dismissing the action against West. View "State v. West" on Justia Law