Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Watson v. State
In 2004, Appellant was found guilty of aggravated robbery and theft of property and sentenced to 264 months’ imprisonment. In 2013, Appellant filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order in his case was void because he was not afforded due process of law. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant’s assertion of a denial of due process was a claim of trial error, and as such, Appellant’s claim was not sufficient to implicate the facial validity of the judgment or the jurisdiction of the trial court.
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Arkansas Supreme Court, Criminal Law
Mathis v. State
After a jury trial, Appellant was found guilty of simultaneous possession of drugs and firearms, possession of a controlled substance, and maintaining a drug premises. After his convictions were affirmed on direct appeal, Appellant filed a pro se petition for postconviction relief, alleging that he was denied due process of law and that he had been denied effective assistance of counsel. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant failed to establish that he received ineffective assistance of counsel; and (2) Appellant was not entitled to relief on the remainder of his claims. View "Mathis v. State" on Justia Law
Holcomb v. State
During an approximately seven-month period, Defendant engaged in online chats with a person identified on Yahoo internet service as “Amanda.” Amanda was actually Detective Donald Eversole, who had set up a profile for a fictional fifteen-year-old girl on an internet-romance chat room. Defendant and Eversole exchanged hundreds of messages through the chat room, which included messages about age and sexual experience and containing photos of each other and sexually explicit exchanges. Defendant was subsequently found guilty by a jury of internet stalking of a child. The Supreme Court reversed, holding that the circuit court erred in denying Defendant’s motion for directed verdict, as there was not substantial evidence to find that Defendant’s conduct satisfied the statutory requirement of acting “in an effort to arrange a meeting.” View "Holcomb v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Haynes v. State
In 1993, Appellant pleaded guilty to attempted rape. In 2013, Appellant filed an application to be relieved of the obligation to register as a sex offender. After a hearing, the trial court denied Appellant’s application on the basis that he had failed to present evidence that he was not likely to pose a threat to the safety of others. The Supreme Court dismissed Appellant’s appeal and declared moot the motion Appellant filed in relation to the appeal, holding that the trial court was not clearly erroneous in finding that Appellant failed to meet his burden of proof required to terminate his obligation to register as a sex offender. View "Haynes v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Gilliland v. State
After a jury trial in 2009, Appellant was found guilty of rape and second-degree sexual assault. Appellant’s convictions were affirmed on appeal. In 2012, Appellant filed a pro se petition to correct his sentence pursuant to Ark. Code Ann. 16-90-111, contending that his sentence was imposed in an illegal manner. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s allegations of ineffective assistance of counsel and claims of trial error did not present grounds for relief under section 16-90-111; and (2) to the extent that any of the issues raised were cognizable in a petition under section 16-90-111 to correct a sentence illegally imposed, because Appellant’s petition was not timely filed, he was not entitled to relief on these claims. View "Gilliland v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Cridge v. Hobbs
Appellant entered a negotiated plea of guilty to manufacturing a controlled substance and was sentenced to 240 months’ imprisonment. Appellant later filed a pro se petition for declaratory judgment and writ of mandamus against the Director of the Arkansas Department of Correction seeking to compel the ADC to recalculate his parole-eligibility date. The circuit court dismissed the petition. Appellant lodged an appeal and subsequently filed a motion to file a belated brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant failed to state a basis for declaratory judgment, and therefore, failed to provide a basis for a writ of mandamus to issue. View "Cridge v. Hobbs" on Justia Law
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Arkansas Supreme Court, Criminal Law
Thomas v. State
After a jury trial, Appellant was convicted of two counts of capital murder and sentenced to death. Appellant’s sentence and conviction were affirmed on appeal. Appellant subsequently filed an Ark. R. Crim. P. 37.5 petition, asserting that his trial counsel provided ineffective assistance. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant’s claim that he received ineffective assistance of counsel on the grounds that his counsel did not object to a change of venue and because his counsel failed to secure and present the testimony of one of the investigating officers of the murders. View "Thomas v. State" on Justia Law
Pitts v. State
After a jury trial, Petitioner was found guilty of second-degree sexual assault and sexual indecency with a child. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, asserting several grounds for the writ. The Supreme Court denied the petition, holding that not only did Petitioner not present sufficient grounds to support issuance or the writ, but his failure to act with due diligence, alone, would constitute good cause to deny the petition. View "Pitts v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Philyaw v. State
After a jury trial in 1981, Petitioner was found guilty of aggravated robbery and sentenced to life imprisonment. Petitioner later 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, contending that he was deprived of due process and his right to trial by an impartial jury and that his counsel provided ineffective assistance at trial. The Supreme Court denied the petition, holding that the sole claim raised in the petition that could fit within the bounds of a coram-nobis proceeding was the assertion of a Brady violation, but none of evidence set forth by Petitioner in support of his claim rose to the level of a Brady violation. View "Philyaw v. State" on Justia Law
Montgomery v. State
Appellant was convicted of the rape of his six-year-old granddaughter and sentenced to twenty-five years’ imprisonment. Following his unsuccessful appeal, Appellant filed a petition for postconviction relief, alleging that his trial counsel rendered ineffective assistance of counsel. The circuit court denied the petition, but the Supreme Court reversed for a hearing. After a hearing, the circuit court again denied relief. The Supreme Court reversed and remanded for a new trial, holding that Appellant was prejudiced by his trial counsel’s failure to object to testimony given by a social worker, which included the social worker’s impermissible opinion on the child victim’s truthfulness and the credibility of the victim’s claims. View "Montgomery v. State" on Justia Law