Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of thirty-seven various sex offenses and sentenced to a total of thirty-seven years incarceration. After Appellant’s convictions were affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that his trial counsel was ineffective for because counsel was simultaneously representing Appellant and Appellant’s wife at the time of Appellant’s trial, and the dual representation created an actual conflict of interest adversely affecting counsel’s performance. The trial court ultimately denied the petition. The Supreme Court reversed, holding (1) an actual conflict of interest existed under the circumstances of this case; and (2) the actual conflict of interest adversely affected counsel’s performance. Remanded for a new trial with conflict-free counsel. View "Rackley v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder, committing a terroristic act, and being a felon in possession of a firearm. Appellant subsequently filed a petition for writ of habeas corpus, apparently contending that the trial court acted without authority and in violation of the state and federal constitutions by modifying the sentence recommended by the jury to add a consecutive sentence for a firearm enhancement. The circuit court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted the motions filed in relation to the appeal because the judgment-and-commitment order reflected the sentence fixed by the jury and ordered by the trial court. View "Frost v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, contending that his sentence was unconstitutional because the trial court admitted his prior juvenile-delinquency adjudication during the sentencing phase as a basis for sentencing him as a habitual offender. The circuit court denied habeas relief. The Supreme Court dismissed Appellant’s appeal without addressing whether Appellant stated a cognizable claim for habeas relief, as it was apparent on the record that prior felony convictions, not juvenile-delinquency adjudications, were used in sentencing Appellant as a habitual offender. View "Davis v. Hobbs" on Justia Law

After a jury trial in 2008, Petitioner was found guilty of aggravated robbery and burglary. Petitioner’s motion for a new trial and petition for postconviction relief were denied. Petitioner subsequently filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court in order that he may proceed with a petition for writ of error coram nobis, claiming (1) his trial counsel was ineffective, (2) newly discovered evidence existed that questioned the credibility of the State’s witnesses, and (3) evidence was withheld by the prosecuting attorney’s office in violation of his constitutional rights, as recognized in Brady v. Maryland. The Supreme Court denied the writ, holding (1) Petitioner’s first two allegations were not a basis for the writ; and (2) Petitioner’s claims of a Brady violation were without merit. View "Burton v. State" on Justia Law

After a jury trial in 1985, Petitioner was found guilty of murder in the first degree and sentenced to life imprisonment. In 1987, the Supreme Court denied Petitioner’s petition to proceed in the trial court with a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Petitioner subsequently filed a second petition to reinvest jurisdiction in the trial court to consider a petition under the version of Rule 37.1 in effect when he became eligible to file a petition. The Supreme Court dismissed the petition and declared moot the motion Petitioner filed in relation to the petition, holding that the petition did not establish any good cause to permit a second petition. View "Alford v. State" on Justia Law

Appellant pleaded guilty to multiple counts of aggravated robbery and theft of property and was sentenced to an aggregate sentence of life imprisonment. Almost twenty years after the judgment had been entered, Appellant filed a pro se petition for writ of error coram nobis. The trial court denied the petition, concluding that the claims were either without merit or not within the purview of a coram-nobis proceeding and that Appellant did not act with due diligence in filing the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the coram-nobis petition. View "Wright v. State" on Justia Law

Appellant pleaded guilty to rape and was sentenced as a habitual offender to 180 months’ imprisonment. Appellant subsequently filed a petition for writ of habeas corpus, making several allegations. The circuit court denied the petition without a hearing, concluding that the allegations were conclusory in nature and failed to state a basis for a writ of habeas corpus to issue. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion to file a belated reply brief, holding that the circuit court did not err when it denied the petition, as Appellant did not establish a basis for a writ of habeas corpus to issue. View "Tolefree v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts of sexual assault of a fourteen-year-old boy. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming dissatisfaction with the trial judge, trial error, and ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted Appellant’s motion for extension of time to file his brief-in-chief, holding (1) the allegations concerning the judge’s conduct did not rise to a showing of fundamental error sufficient to void the judgment; (2) Appellant failed to establish that his attorney was ineffective; and (3) Appellant did not establish that any claim of trial error raised in the petition was sufficient to void the judgment in his case. View "Nelson v. State" on Justia Law

In 1986, Petitioner was found guilty of three felony offenses for which the circuit court imposed an aggregate sentence of life imprisonment. The Supreme Court affirmed. In 2013, Petitioner filed a pro se petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court held that none of Petitioner’s claims was sufficient to void the judgment-and-commitment order and denied the petition. Petitioner subsequently filed a second Rule 37.1 petition, alleging several claims of error that were raised in his original Rule 37.1 petition. The Supreme Court dismissed the petition, holding that Petitioner did not raise a claim sufficient to void the judgment in his case. View "Munnerlyn v. State" on Justia Law

After a jury trial, Appellant was found guilty of murder in the second degree and sentenced as a habitual offender to 540 months’ imprisonment. Appellant subsequently filed a petition for postconviction relief seeking to vacate the judgment. Appellant’s signature on the petition was notarized, but the petition was not verified in accordance with Ark. R. Crim. P. 37.1(c). After a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that because Appellant’s petition was not in compliance with Rule 37.1(c), it did not act to confer jurisdiction on the trial court to consider the merits of the petition. View "Mason v. State" on Justia Law