Justia Arkansas Supreme Court Opinion Summaries

After a jury trial in 2001, Appellant was found guilty of first-degree murder and sentenced to an aggregate term of 540 months’ imprisonment. In 2012, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2011 as amended, asserting that, despite his confession to the crime during the investigation, scientific testing would show his actual innocence. The circuit court denied the petition, concluding that Appellant failed to rebut the presumption against timeliness. The Supreme Court affirmed, holding that Appellant did not establish good cause for the approximate eleven-year delay in filing his petition, and therefore, the circuit court did not err in denying Appellant’s petition without a hearing. View "Biggs v. State" on Justia Law

A police officer stopped Defendant for driving with a defective passenger taillight. The officer subsequently arrested Defendant and charged him with driving while intoxicated (DWI), among other offenses. Defendant filed a motion to suppress, arguing that there was no probable cause for the initial traffic stop. The circuit court denied the motion, concluding that there was reasonable cause for the traffic stop. After a jury trial, Defendant was convicted of refusal to submit to a chemical test but was acquitted of the DWI charge. Defendant appealed the denial of his motion to suppress, arguing that because there is no Arkansas statute prohibiting a cracked taillight, the officer did not have probable cause to stop his vehicle. The Supreme Court affirmed, holding (1) the fact that Defendant’s taillight was visibly broken was sufficient probable cause to believe that he may have committed a traffic violation; and (2) therefore, the circuit court correctly concluded that there was probable cause for the officer to stop Defendant. View "Robinson v. State" on Justia Law

After a jury trial, Petitioner was convicted of aggravated assault on a family or household member, among other charges. The court of appeals reversed and remanded. On remand, Petitioner sought postconviction relief under Ark. R. Crim. P. 37, arguing that his counsel provided ineffective assistance. The circuit court denied Hayes’s petition. Petitioner appealed from that ruling and then filed a motion to reconsider. The Supreme Court affirmed, holding (1) if any of Petitioner’s allegations were not ruled on by the circuit court, his failure to seek a writ of mandamus barred further action; and (2) the circuit court did not err in finding that Petitioner was not prejudiced by any error on the part of trial counsel. View "Hayes v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. After the conviction was affirmed on appeal and Appellant unsuccessfully filed a petition for writ of habeas corpus, Appellant filed a second petition for habeas relief, alleging that his counsel provided ineffective assistance and that he was being illegally detained. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to provide any factual support for his allegations, and the circuit court did not err in failing to hold a hearing on the petition. View "Buchanan v. Hobbs" on Justia Law

In 1972, Appellant pled guilty to murder in the first degree and was sentenced to life imprisonment. In 2012, Appellant filed a petition for writ of error coram nobis, asserting that his guilty plea was not voluntarily entered because it was the product of coercion and because his counsel had operated under a conflict of interest at the time the plea was entered. The circuit court denied Appellant’s petition. The Supreme Court affirmed, holding that Appellant’s claims were actually predicated on allegations of ineffective assistance of counsel, and his allegations were not cognizable in a proceeding for error coram nobis. View "Nelson v. State" on Justia Law

In 2005, Appellant pleaded guilty to charges of theft by receiving, being a felon in possession of a firearm, and possession of a controlled substance with intent to deliver. Appellant received a ten-year suspended sentence on each count, but, in 2009, the trial court revoked Appellant’s suspended imposition of sentence for Appellant’s failure to meet the conditions under which the sentence was suspended. In 2013, Appellant filed a petition for writ of habeas corpus alleging that he was not afforded effective assistance of counsel when he entered his guilty plea and that the 2005 ten-year suspended imposition of sentence was an illegal sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish a basis for a writ of habeas corpus to issue. View "Murry v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of capital felony murder and sentenced to life imprisonment without the possibility of parole. After Appellant’s conviction was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that (1) some of Appellant’s claims were conclusory and raised for the first time on appeal and thus not subject to review; and (2) the remainder of Appellant’s claims of error were without merit. View "Dixon v. State" on Justia Law

In 1987, Petitioner pleaded guilty in two cases to two counts of burglary and two counts of theft of property. Petitioner was placed on ten years’ probation. In 2010, Petitioner filed a petition for writ of error coram nobis in the two cases, which the trial court denied. Petitioner subsequently filed a motion for reconsideration, which was denied. Petitioner subsequently sought leave to proceed with a belated appeal from the denial of his petition for writ of error coram nobis. The Supreme Court dismissed Petitioner’s motion, holding that because Petitioner had served his sentence by the time he filed the petition, his claim was moot. View "Williford v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to life imprisonment. A notice of appeal was filed, but Appellant’s appellate counsel, a full-time public defender, asked that she be relieved as counsel on the ground that she was ineligible for compensation for services as appellate counsel. The Supreme Court granted counsel’s motion to be relieved because, where counsel was a full-time public defender with a full-time, state-funded secretary, counsel was not entitled to be paid for services in this appeal under Ark. Code Ann. 19-4-1604(b)(2)(B). View "Turner v. State" on Justia Law

After a jury trial, Petitioner was found guilty of capital murder and aggravated robbery and sentenced to an aggregate term of life without parole. The Supreme Court affirmed on appeal. 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, asserting trial error and complaining about the length of his sentence. The Supreme Court denied the petition, holding that Petitioner’s assertions were not sufficient to demonstrate any extraordinary circumstances warranting reopening the direct appeal of the judgment of conviction in this case. View "Travis v. State" on Justia Law