Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of capital murder, for which he was sentenced to a term of life imprisonment without the possibility of parole, and other offenses. On appeal, Appellant argued that the circuit court erred by not allowing him to cross-examine his codefendant about her prior misdemeanor third-degree domestic battery conviction for having stabbed Appellant. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in excluding the evidence, as (1) the testimony had very little probative value relating to the codefendant’s alleged bias against Appellant; (2) Appellant failed to establish that the evidence was proper modus operandi evidence; and (3) Appellant failed to put forth evidence to make a defense that the codefendant was the person who stabbed the victim. View "Lewis v. State" on Justia Law

Appellee, who was seventeen years old at the time of the offenses, pled nolo contedere to committing several crimes, including kidnapping. The circuit court sentenced Appellee to life imprisonment for his kidnapping conviction. The U.S. Supreme Court subsequently issued its decision in Graham v. Florida, holding that the Eighth Amendment forbids a sentence of life without parole for a juvenile offender who did not commit homicide. Appellee subsequently filed a writ of habeas corpus alleging that, pursuant to Graham, his life sentence was unconstitutional. After a sentencing hearing, the circuit court sentenced Appellee to a term of forty years’ imprisonment for the kidnapping conviction. The State appealed, arguing that the circuit court erred in not sentencing Appellee to a term of life imprisonment with the possibility of parole. Appellee cross-appealed. The Supreme Court affirmed, holding (1) the circuit court correctly ruled that the maximum sentence available after invalidation of Appellee’s life sentence was forty years; and (2) Graham did not entitle Appellee to additional consideration of his youth or the circumstances of his crime to reduce his sentence even further. View "Hobbs v. Turner" on Justia Law

After a jury trial, Appellant was found guilty of possession of a controlled substance with intent to deliver. Appellant later filed a pro se petition for writ of habeas corpus, contending (1) he was subjected to an illegal search and seizure of evidence and an illegal arrest, and (2) insufficient evidence supported the judgment as revealed in contradictory testimony of witnesses at trial. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared moot the motion filed in relation to the appeal, holding that 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 "Green v. State" on Justia Law

After a jury trial, Appellant was found guilty of domestic battery in the first degree. Appellant subsequently filed a pro se petition for postconviction relief, which the trial court denied without a hearing. The Supreme Court affirmed the denial, holding (1) the trial court did not err by not appointing an attorney to represent Appellant on his postconviction petition; (2) Appellant’s challenge to his sentence was not cognizable in a postconviction proceeding; and (3) the trial court did not err in holding that Appellant’s counsel did not provide ineffective assistance under the standard set forth in Strickland v. Washington. View "Ellis v. State" on Justia Law

Petitioner was found guilty of kidnapping and sentenced to 240 months’ imprisonment. The court of appeals affirmed. Petitioner subsequently filed a petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he could proceed with a petition for writ of error coram nobis, alleging that he was returned to prison on a case that had been dismissed in 1996. The Supreme Court denied the petition, holding that Petitioner was not entitled to relief because his claim did not fit any of the categories within the purview of a coram nobis proceeding. View "Zulpo v. State" on Justia Law

Defendant entered a conditional guilty plea to trafficking a controlled substance. The court of appeals affirmed. Defendant subsequently filed a petition for review, arguing that the circuit court erred in failing to suppress evidence seized during a traffic stop of the rental cae Defendant was driving because the law enforcement’s placement of a GPS tracking device on the vehicle without a warrant and gathering data about the vehicle’s movements was an unconstitutional search under United States v. Jones. The Supreme Court affirmed without considering Defendant’s argument that planting the GPS device was an unreasonable search under Jones, holding (1) Defendant had no legitimate expectation of privacy in the vehicle and no standing to challenge the search of the rental car; and (2) although Defendant had standing to challenge his own detention, the detention was reasonable. View "Wilson v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, raising multiple allegations of ineffective assistance of counsel. The trial court denied the petition without a hearing. The Supreme Court reversed, holding that the trial court’s order denying Appellant’s Rule 37.1 petition was inadequate because it did not contain sufficient written findings to sustain conclusively the trial court’s decision that Appellant was entitled to no relief. Remanded. View "Walden v. State" on Justia Law

After a jury trial, Petitioner was found guilty of rape and terroristic threatening in the first degree. The court of appeals affirmed. Petitioner subsequently filed a petition requesting that jurisdiction be reinvested in the trial court so that he may proceed with a petition for writ of error coram nobis, alleging in relevant part that the State withheld exculpatory evidence from the defense in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) Petitioner did not meet his burden of demonstrating a ground for the writ; and (2) Petitioner did not establish that he exercised due diligence in bringing forth his claims for relief. View "Patrick v. State" on Justia Law

After a jury trial, Defendant was found guilty of capital murder and sentenced to death. The Supreme Court affirmed Defendant's conviction and sentence. Later, Defendant petitioned the Supreme Court to reinvest jurisdiction in the circuit court to allow him to seek a writ of error coram nobis, alleging that he was incompetent at the time of trial and that the prosecutor had withheld exculpatory evidence in violation of Brady v. Maryland. The Court granted Defendant permission to pursue coram nobis relief on both grounds. The circuit court denied the petition for writ of error coram nobis, finding that Defendant had been competent to stand trial and that the prosecution did not fail to disclose exculpatory evidence. The Supreme Court reversed, holding that the circuit court abused its discretion in denying Defendant’s petition where the record illustrated that Defendant’s cognitive deficits and mental illnesses interfered with his ability to effectively and rationally assist counsel. Remanded for a new trial. View "Newman v. State" on Justia Law

After a jury trial, Petitioner was found guilty of several offenses, including rape and kidnapping. The court of appeals affirmed. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition and an amended petition requesting that the Supreme Court reinvest jurisdiction in the trial court so that he could proceed with a petition for writ of coram nobis. The Supreme Court denied the petition and amended petition and declared the motions filed in connection with the petitions moot, holding that Petitioner’s allegations did not warrant issuance of a writ of error coram nobis. View "Hooper v. State" on Justia Law