Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of premeditated and deliberated capital murder and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, alleging that his trial attorney provided ineffective assistance. The circuit court denied the petition after an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant failed to meet his burden of establishing that he was entitled to appointment of counsel in his postconviction proceedings; and (2) the circuit court did not abuse its discretion in denying Appellant’s motion to file an enlarged petition. View "Evans v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. Appellant was sentenced to life imprisonment without parole. On appeal, Appellant argued that the trial court erred when it admitted into evidence an out-of-court statement by a witness to a police detective. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due, in part, to trial counsel’s failure to confront the witness in cross-examination. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in connection with the appeal, holding that Appellant failed to demonstrate that counsel provided ineffective assistance. View "Davis v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder, attempted capital murder, and possession of a controlled substance. Defendant was sentenced to death for the murder conviction. The Supreme Court affirmed Defendant’s convictions and sentences, holding that the circuit court did not commit reversible error by (1) allowing the State to present evidence of bad acts and bad character; (2) admitting two photographs of a large tattoo on Defendant’s back; (3) permitting repeated showings of dash-camera videos depicting the crimes as they took place; (4) failing to sequester victim-impact witnesses during the guilt phase of trial; (5) overruling Defendant’s objection to a comment the prosecuting attorney made at the sentencing phase of trial; and (6) denying Defendant’s motion to prohibit the State from seeking or imposing the death penalty. View "Lard v. State" on Justia Law

After a jury trial in 2006, Appellant was convicted of capital murder, aggravated robbery, attempted arson, and theft of property. Appellant was sentenced to an aggregate term of life imprisonment without parole plus 636 years. In 2013, Appellant filed a pro se motion for a new sentencing hearing, asserting that her trial counsel erred by not informing her of a plea bargain offered by the prosecution until after she had been convicted. The trial court denied the motion. The Supreme Court affirmed on the basis that the petition was not timely filed, and therefore, the trial court had no jurisdiction to grant the relief sought. View "Young v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a pro se petition for declaratory judgment and injunctive relief against Appellees, certain ADC correctional officers, alleging excessive use of force, negligence, failure to protect, and due-process and equal-protection violations. The circuit court granted Appellees' motion to dismiss on the ground that allowing Appellant to proceed with the action in forma pauperis would violate the three-strike rule embodied in Ark. R. Civ. P. 9(b). Appellant appealed, arguing that the circuit court erred in dismissing his complaint and that the "imminent danger" exception to the three-strike rule applied. The Supreme Court affirmed, holding that Appellant failed to demonstrate any error in the dismissal of his complaint. View "Pitts v. Rafter" on Justia Law

In 1981, Appellant and two other persons were charged with capital felony murder and attempted capital felony murder. The jury only returned a sentence of life imprisonment on the capital-felony-murder charge. In 2010, Appellant filed a petition to reinvest jurisdiction in the trial court to consider a petition pursuant to Ark. R. Crim. P. 37.1, arguing that the sentence imposed for the capital felony murder was void. The Supreme Court denied the petition. In 2012, Appellant filed a pro se motion to adjust sentence, alleging that the trial court erred by failing to instruct the jury to impose separate sentences for capital murder and attempted capital murder. The trial court dismissed the petition. The Supreme Court affirmed, holding that postconviction relief was unavailable because Appellant filed the motion to adjust the sentence in the trial court without having obtained the Supreme Court's leave to do so. View "Moss v. State" on Justia Law

Defendant was convicted of one count of rape and four counts of possession of drug paraphernalia. More than ninety days after Defendant's conviction, Defendant's trial counsel filed a notice of appeal and did not file an extension to complete the record. Defendant filed a motion for rule on clerk, contending that his appeal was filed late as a result of his attorney's failure to request an extension to complete the record. The Supreme Court remanded to the circuit court for a determination as to whether the attorney was asked to perfect the appeal. On remand, the circuit court found that the attorney had been asked to perfect the appeal. The Supreme Court subsequently granted Defendant's second motion for rule on clerk, as he showed good cause to proceed. View "McCulley v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced as a habitual offender to life imprisonment. Appellant appealed, arguing that the circuit court erred in denying his motion to suppress an incriminating statement that he made after he unequivocally invoked his right to remain silent. The Supreme Court affirmed, holding that Appellant's statement that he had already told officers all the he knew during an interrogation was not an unambiguous and unequivocal invocation of his right to remain silent, and therefore, the trial court did not err in denying the motion to suppress. View "Fritts v. State" on Justia Law

Appellant entered a negotiated plea of guilty to multiple felony offenses. Four years later, Appellant filed a pro se petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel in the plea proceeding and that the trial court did not follow proper procedure when the guilty plea was entered. The trial court denied the petition. The Supreme Court dismissed Appellant's appeal and declared his motion for extension of time to file his brief-in-chief moot, holding (1) Appellant's ineffective assistance of counsel claim was not within the purview of a coram-nobis proceeding; and (2) Appellant's argument regarding the trial court's procedure could have been raised at the time the plea was entered, and Appellant's claim that his plea was coerced did not demonstrate that a writ of error coram nobis should issue. View "Edwards v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder and three counts of unlawful discharge of a firearm from a vehicle. Because the State waived the death penalty, the circuit court automatically sentenced Defendant to life imprisonment without the possibility of parole for his capital murder conviction. The circuit court also sentenced Defendant as a habitual offender to terms of imprisonment for the unlawful-discharge convictions and for a firearm enhancement. Defendant appealed, claiming that his counsel was ineffective for failing to object when the circuit court, instead of the jury, assessed the sentences for the firearm enhancement and the unlawful-discharge convictions. The circuit court denied the petition. The Supreme Court reversed and remanded because the circuit court failed to make adequate findings of fact on this issue. On remand, the circuit court again denied Defendant's petition for postconviction relief. The Supreme Court affirmed because Defendant did not assert any claim of prejudice, which made it unnecessary for the Court to review the circuit court's finding that counsel's representation was not deficient. View "Davenport v. State" on Justia Law