Justia Arkansas Supreme Court Opinion Summaries

After a jury trial in 1988, Appellant was convicted of capital murder, aggravated robbery, and theft of property. Appellant was sentenced to life imprisonment for the murder conviction. In 1991, Appellant’s convictions for aggravated robbery and theft of property were set aside. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging trial error and ineffective assistance of counsel claims and that the trial court lacked jurisdiction because it entered an amended judgment. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, and therefore, Appellant did not establish a basis for a writ of habeas corpus to issue. View "Davis v. State" on Justia Law

After a jury trial, Appellant was found guilty of several offenses, including first-degree murder. The case was reversed and remanded. After a retrial, Appellant was again found guilty of first-degree murder and related offenses. Appellant was sentenced to life imprisonment for the first-degree murder conviction. Appellant later filed a pro se petition for writ of habeas corpus, arguing that his life sentence for the murder conviction was illegal because he was a juvenile at the time of the crime. The circuit court dismissed the petition on the grounds that it did not conform to pleading rules. The Supreme Court dismissed Appellant’s appeal and mooted the motions filed in relation to the appeal, holding that, pursuant to Murry v. Hobbs, because Appellant’s life sentence for first-degree murder was not mandatory, this sentence was not illegal under Miller v. Alabama. View "Britt v. State" on Justia Law

After a jury trial, Appellant was found guilty of committing two counts of Class Y felony terroristic acts, four counts of Class B felony terroristic acts, and two counts of battery in the first degree. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging trial error and that his attorney provided ineffective assistance. The trial court denied the petition without a hearing. Appellant appealed, arguing that the trial court erred in denying the petition without a hearing. The Supreme Court affirmed, holding that the trial court did not err in denying relief without holding a hearing. View "Armstrong v. State" on Justia Law

After a jury trial in 2003, Appellant was found guilty of capital murder and first-degree battery and sentenced to an aggregate term of life imprisonment without parole. In 2013, Appellant filed a pro se petition for declaratory judgment pursuant to Ark. Code Ann. 16-111-102 seeking to overturn the judgment by challenge the sufficiency of the evidence, claiming he was denied his due process rights, and alleging trial error. The circuit court dismissed the petition, concluding that Appellant had not stated a ground for declaratory judgment. The Supreme Court dismissed the appeal and declared the motions filed in relation to the appeal moot, holding that Appellant’s attempt to convert the declaratory-judgment statute into a postconviction remedy was not founded on proper procedure. View "Grant v. Hobbs" on Justia Law

The Legislative Auditor subpoenaed Appellant to appear and testify during a meeting of the Legislative Joint Auditing Committee’s Standing Committee on Counties and Municipalities, but Appellant failed to appear. The Auditor subsequently filed a petition for adjudication of contempt. The circuit court eventually entered an order finding Appellant guilty of criminal contempt and issued a $250 fine. The Supreme Court affirmed, holding that the circuit court did not err (1) in denying Appellant’s motion to dismiss for lack of service pursuant to Ark. R. Civ. P. 4; (2) in ruling that the subpoena was a valid subpoena; and (3) in finding Appellant in criminal contempt. View "Valley v. Pulaski County Circuit Court" on Justia Law

After a jury trial, Appellant was found guilty of aggravated residential burglary and use of a firearm in the commission of the offense. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of stating facts that affirmatively supported his claims of prejudice, and accordingly, the trial court did not err in denying relief; and (2) the trial court did not err in denying the petition without an evidentiary hearing. View "Thornton v. State" on Justia Law

In 1989, Appellee pled guilty to one count of first-degree sexual abuse. In 2013, Appellee filed a motion asking the circuit court to terminate his obligation to register as a sex offender. The circuit court granted the motion and denied the State’s subsequent motion for reconsideration. The State appealed, contending that the circuit court clearly erred in concluding that Appellee was not likely to pose a threat to the safety of others and therefore could be relieved of his obligation to register as a sex offender. The Supreme Court affirmed the circuit court’s decision terminating Appellee’s obligation to register as a sex offender, holding that the circuit court did not clearly err in concluding that Appellee had proved by a preponderance of the evidence that he was not likely to pose a threat to the safety of others. View "State v. Khabeer" on Justia Law

After a jury trial, Appellant was convicted of three counts of rape and sentenced to forty years’ imprisonment on each count, with the sentences to be served concurrently. On appeal, Appellant argued that the circuit court erred (1) in permitting the State to introduce pornographic images from Appellant’s computer without sufficient evidence that he viewed the pornography; (2) in admitting the pornographic images under Ark. R. Evid. 404(b); and (3) in concluding that the probative value of the evidence outweighed its prejudicial effect under Ark. R. Evid. 403. The Supreme Court affirmed, holding that any error in the admission of the images by the circuit court was harmless. View "Johnston v. State" on Justia Law

In 2010, Appellant was found guilty by a jury of delivery of cocaine and sentenced to 900 months’ imprisonment. The trial court vacated Appellant’s sentence. Appellant was subsequently resentenced pursuant to a negotiated guilty plea, and a sentence of 420 months’ imprisonment was imposed. The 2012 sentencing order reflected that Appellant received 805 days of jail-time credit. In 2013, Appellant filed a motion asserting that, in the 2012 sentencing order, the trial court erroneously denied him the benefit of 785 days of earned credit for meritorious good time. The trial court denied the motion. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s request for relief was directed toward the calculation of his accrual of meritorious good time, which was a matter of parole eligibility to be determined by the Arkansas Department of Correction; and (2) to the extent that Appellant’s claim could be construed as one for modification of his sentence, the motion was untimely filed. View "Green v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of rape and one count of attempted rape of a minor. Appellant subsequently filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel as well as trial errors based on the admission of a coerced confession, a violation of the prohibition against double jeopardy, and the filing of a defective information. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant’s appeal and declared moot the motions Appellant filed in relation to the appeal, holding (1) trial counsel did not provide constitutionally defective assistance; and (2) Appellant was not entitled to relief on his remaining allegations. View "Dodge v. State" on Justia Law