Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of drug-related offenses. Appellant was sentenced to an aggregate term of life imprisonment. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging, among other things, that the judgment violated the prohibition against double jeopardy and that he was denied the effective assistance of counsel, his right to a speedy trial, and the right to conduct his own defense. The circuit court denied the petition. The Supreme Court dismissed appeal and mooted Appellant's motions related to the appeal, holding that none of Appellant's claims were grounds for issuance for the writ. View "Watts v. State" on Justia Law

Appellant entered a negotiated plea of guilty to robbery and overdraft. The circuit court sentenced Appellant to 300 months' imprisonment to run consecutive to his parole violation. Appellant appealed and filed motions for transcript and for extension of time to file brief. Appellant subsequently filed a pro se petition to correct an illegal sentence, which the circuit court denied as untimely. The Supreme Court dismissed the appeal and mooted the motions, holding (1) the claims raised in Appellant's petition did not allege an illegal type of sentence that was jurisdictional in nature, but rather made allegations that should have been raised at trial or in a timely petition pursuant to Ark. R. Crim. P. 37.1; and (2) Appellant's petition was also untimely under Ark. Code Ann. 16-90-111. View "Stanley v. State" on Justia Law

Petitioner was arrested in 2011 and detained in jail, where he remained since his arrest. Petitioner was later charged with aggravated robbery and capital murder. In 2013, Petitioner filed a second amended petition for writ of habeas corpus against the county sheriff, seeking his release from custody and asserting that his continued detainment violated his due process rights because the prosecutor announced there was insufficient evidence to move forward with the case. The Supreme Court denied the petition because none of the allegations raised by Petitioner called into question the trial court's jurisdiction or established that the commitment was invalid on its face. View "Smith v. Smith" on Justia Law

Petitioner was charged with aggravated robbery and capital murder. The elected prosecutor unsuccessfully moved to nolle pros the case against Petitioner due to the main eyewitness's unavailability. The circuit court subsequently disqualified the elected prosecutor and appointed a special prosecutor, finding that the elected prosecutor disqualified himself by seeking not to prosecute Petitioner when there was evidence to support the prosecution. Petitioner subsequently filed an amended petition for writ of prohibition or, in the alternative, writ of certiorari. The Supreme Court denied the writ of prohibition but granted the writ of certiorari, holding (1) the circuit court exceeded its jurisdiction by disqualifying the elected prosecutor and appointing a special prosecutor; but (2) the writ of certiorari did not lie with regard to the circuit court's denial of the motion to nolle pros. View "Smith v. Simes" on Justia Law

After a trial in the Saline County Circuit Court in 1987, Appellant was convicted of kidnapping and sentenced to 240 months' imprisonment. In 2013, Appellant filed a "motion to order release due to court order from 1996" in the circuit court in Lee County, where he was in custody. The circuit court denied the petition, concluding that it constituted a challenge to the judgment of conviction entered in the Saline County trial court and should have been filed there. The Supreme Court affirmed, holding that whether Appellant's motion was intended to be in the nature of a petition for writ of habeas corpus or a petition for postconviction relief, the circuit court was not wrong to dismiss the motion. View "Zulpo v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed on appeal. Prior to issuance of the mandate, Appellant filed a pro se petition for postconviction relief, alleging that his counsel had provided constitutionally deficient assistance for several reasons. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant's appeal and moot his motion for extension of time to file his brief because it was clear Appellant could not prevail if his appeal were permitted to go forward. View "Jordan v. State" on Justia Law

Petitioner filed a pro se petition for writ of habeas corpus in the circuit court in Lee County, where he was incarcerated. Thereafter, Petitioner was transferred to a facility in a different county. The circuit court dismissed Petitioner's petition. Petitioner filed a notice of appeal and moved to proceed with a belated appeal and to complete the record. The Supreme Court dismissed the motion for belated appeal and mooted the motion to complete the record, holding that because Petitioner was not in custody in the Lee County Circuit Court's jurisdiction, the Lee County Circuit Court did not retain personal jurisdiction over Petitioner and could no longer grant the relief sought. View "Fields v. State" on Justia Law

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC) at a facility in Lincoln County, filed a pro se petition for writ of habeas corpus in the Pulaski County Circuit Court. Thereafter, Appellant filed a motion to dismiss the habeas petition and filed a second petition for habeas corpus. Appellant subsequently filed a series of motions and pleadings in the case. The circuit court dismissed the first habeas petition, denied the second habeas petition, and denied or dismissed motions and pleadings filed in the habeas proceeding. The Supreme Court dismissed Appellant's appeal and held the motion related to the appeal moot, holding that because Appellant was not incarcerated in Pulaski County, the Pulaski County Circuit Court did not have jurisdiction to release Appellant on a writ of habeas corpus. View "Pitts v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree sexual assault and sexual indecency with a child. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus seeking to challenge the calculation of his parole eligibility. The circuit court dismissed the petition. Appellant appealed and filed a pleading arguing that his sentence should be dismissed as unconstitutional on the ground that the trial judge did not follow federal sentencing guidelines. Appellant also argued that the circuit court lacked jurisdiction and that he was being held pursuant to an invalid conviction. The Supreme Court dismissed the motion and affirmed the circuit court's order, holding that Appellant failed to show he was entitled to declaratory judgment or a writ of mandamus, and his motion was without merit. View "Pitts v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of the rape of his stepdaughter and sentenced to 156 months' imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his counsel provided ineffective assistance, for, among other things, deciding not to introduce a recording into evidence for the purpose of impeaching the victim. The trial court found that Appellant was not entitled to relief on the allegation because Appellant failed to identify specific evidence that would have changed the outcome of the trial and because the introduction of evidence is a matter of trial strategy. The Supreme Court reversed the trial court on this point and remanded for an evidentiary hearing, as it was not apparent from the face of the petition or the record that Appellant was not entitled to relief on this allegation. View "Lemaster v. State" on Justia Law