Justia Arkansas Supreme Court Opinion Summaries

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

After a bench trial, Appellant was convicted of first- and second-degree battery. The court of appeals affirmed on appeal. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming that his trial counsel was ineffective for several reasons, that the circuit court erred in denying relief on his claims of constitutional error, and that the circuit court did not make required findings of fact and conclusions of law. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in its judgment. View "Moten v. State" on Justia Law

Appellant was convicted of two counts of aggravated robbery, two counts of theft of property, and one count of second-degree battery. After the court of appeals affirmed on direct appeal, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective (1) for failing to move for a directed verdict at trial, as a directed-verdict motion would not have been successful; (2) for "opening the door" to certain testimony, as counsel's tactical decision about how to cross-examine the witness was supported by reasonable professional judgment; and (3) in investigating and preparing Appellant's case. View "Mason v. State" on Justia Law

Appellant entered a negotiated plea of guilty to two counts of murder in the first degree, attempted murder in the first degree, and battery in the first degree after crashing his truck into his estranged wife's vehicle, killing a pregnant passenger and her unborn daughter. A jury was empaneled to determine Appellant's sentence. The Supreme Court affirmed the sentence imposed, holding (1) Appellant's argument that the circuit court erred in admitting certain Ark. R. Evid. 404(b) evidence in the sentencing phase was not preserved for appeal; and (2) the circuit court did not err by failing to grant a mistrial after certain comments were made by the prosecutor during closing statements. View "Johnson v. State" on Justia Law

After a jury trial in 1992, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In 2011, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, seeking scientific testing of a cigarette butt found in an ashtray at the victim's home where the victim's body was discovered. The trial court denied the petition. The Supreme Court affirmed, holding that the testing of the cigarette butt would not produce new material evidence or raise a reasonable probability that Appellant did not commit the murder, and therefore, Appellant was not entitled to have the cigarette butt tested pursuant to Act 1780. View "Hall v. State" on Justia Law

After a second jury trial in 2012, Appellant was convicted of four counts of capital murder and one count of kidnapping. Appellant was sentenced to four terms of life imprisonment without the possibility of parole for the capital-murder convictions. Appellant's original convictions and sentences were reversed and remanded by the Supreme Court based on the circuit court's error in allowing the State to present reputation and other bad-acts evidence. The Supreme Court affirmed Appellant's 2012 convictions and sentences, holding, among other things, that the circuit court did not prejudicially err when it (1) denied Appellant's motion for directed verdicts for capital murder and kidnapping; (2) admitted out-of-court statements made by Appellant's son; (3) denied Appellant's motion for mistrial; (4) gave jury instructions on accomplice liability; (5) denied Appellant's challenge to a certain juror for cause; (6) failed to rule on Appellant's motion to settle the record; and (7) amended its judgment-and-sentencing order. View "Green v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a pro se civil-rights action against Appellees, two ADC officers, pursuant to 42 U.S.C. 1983, alleging use of excessive force and failure to protect as well as abuse of authority. Appellant also alleged state-law claims of assault and battery and negligence. The trial court dismissed the case on the basis that the claims were barred by the statute of limitations and immunity. The Supreme Court affirmed, holding that Appellant's claims were barred by the statute of limitations, and therefore, it was unnecessary to reach the issue of immunity or to address Appellant's remaining points on appeal. View "Early v. Baker" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery and theft of property. No appeal was taken. Appellant later filed a pro se petition for writ of error coram nobis, alleging that the trial court erred in declining to grant a continuance, to consider certain proof that Appellant was mentally deficient, to admit certain evidence at trial, and to suspend proceedings so a psychological evaluation could be conducted on Appellant. The trial court court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that because Appellant did not raise a claim within the scope of a coram-nobis proceeding, the trial court did not err in denying the petition. View "Croston v. State" on Justia Law

Appellant entered a negotiated plea of guilty or nolo contendere to rape. Appellant later filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, claiming that scientific evidence was available to show his actual innocence and that his arrest was illegal. The trial court denied the motion, finding that the petition was untimely and that Appellant offered no scientific evidence in support of his allegation. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding (1) considering Appellant's unsubstantiated claim that merely alleged the availability of scientific evidence, the trial court did not err in denying relief; and (2) dismissal of the petition was proper because it was not timely filed. View "Winnett v. State" on Justia Law