Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Pedraza v. Circuit Court
Petitioner was charged with capital murder and permitting the abuse of a minor by felony information on March 20, 2012. Petitioner pled not guilty to the charges, and the court set the case for jury trial on October 22, 2012. Citing trouble obtaining military records for mitigation purposes, Petitioner filed a motion for continuance. The court denied the motion without prejudice. On September 27, 2012, Petitioner filed a renewal of his motion for continuance, citing various objections. After a hearing, the court found that Defendant had failed to make the requisite factual showing and denied the motion. Thereafter, Petitioner filed a petition for writ of certiorari, maintaining that because of the special circumstances of this case - a complex death penalty case slated for trial merely six months after Petitioner was afforded the benefit of counsel - the Court should grant relief. The Supreme Court denied the writ because Petitioner had another adequate remedy at law - an appeal. View "Pedraza v. Circuit Court" on Justia Law
Paige v. Circuit Court (Reynolds)
Petitioner filed a pro se petition for writ of mandamus in the Supreme Court, alleging that the circuit court judge failed to act in a timely manner on a petition for postconviction relief Petitioner filed in 2009. While the judge was unable to determine the exact cause of the delay, the Supreme Court concluded that the delay was an anomaly resulting from clerical error rather than the consequence of a failure to have appropriate procedures in place. The Court then declared the petition for mandamus moot because the underlying petition was acted on by the circuit court. View "Paige v. Circuit Court (Reynolds)" on Justia Law
Fields v. State
Defendant was convicted and sentenced in the underlying criminal case. Defendant subsequently filed a pro se motion seeking leave to file a pro se petition for rehearing, challenging the admissibility of certain evidence and the sufficiency of the evidence to sustain the judgment, and arguing that his trial counsel provided ineffective assistance. The Supreme Court denied the motion, as Petitioner was represented by counsel on appeal who did not elect to file a petition for rehearing, and Petitioner's claim of ineffective assistance of counsel was not properly raised in a belated petition for rehearing. View "Fields v. State" on Justia Law
Davis v. State
Appellant was convicted of several counts of breaking or entering and theft of property and sentenced to 480 months' incarceration. After the judgment was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, raising a number of claims, including ineffective assistance of counsel and due-process violations. The trial court denied the petition, finding that Appellant had failed to present proof to support each of his claims. Appellant appealed and then filed a motion for an extension of time in which to file his brief and five other motions, all of which indicated an intention to supplement the record. The Supreme Court (1) granted in part, denied in part, and declared moot in part Appellant's motions to supplement; (2) declared moot Appellant's motion for extension of time; and (3) dismissed the appeal, holding that the trial court's findings in its order denying postconviction relief were not clearly erroneous, and Appellant could not prevail on appeal.
View "Davis v. State" on Justia Law
Townsend v. State
Appellant filed in the circuit court a pro se petition for postconviction relief. Appellant indicated in the heading to the petition that the petition encompassed six cases, and Appellant further indicated that he had entered pleas of guilty to felony offenses in the six cases. The trial court denied the petition. Appellant lodged an appeal and filed a motion for an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the record on appeal was clearly deficient because it contained only one judgment, and therefore, the record was not sufficient to determine if the issues for reversal were well founded or if the petition was timely filed as to every judgment. View "Townsend v. State" on Justia Law
Stevenson v. State
After a jury trial, Defendant was convicted of the first-degree murder of Michael Fox, who suffered three stab wounds. Defendant was sentenced to life in prison. The Supreme Court affirmed the conviction and sentence, holding that the circuit court (1) did not err in denying Defendant's directed-verdict motion, as substantial evidence supported the verdict; (2) did not err in denying Defendant's motion to suppress his statement to a police officer; (3) did not abuse its discretion in denying Defendant's motion for mistrial; (4) did not abuse its discretion in denying Defendant's motions to exclude prior bad acts involving Defendant's use of a knife; and (5) did not abuse its discretion in failing to exclude a plaster cast of the knife impression found in a seized knife box. View "Stevenson v. State" on Justia Law
McDaniel v. Hobbs
Petitioner filed a pro se petition for writ of habeas corpus in the circuit court where he was incarcerated. The circuit court dismissed the petition on May 31, 2012, and Petitioner sought reconsideration. The motion for reconsideration was denied on July 31, 2012. Petitioner did not file a notice of appeal from either order and sought leave in this motion to proceed with a belated appeal. The Supreme Court denied the motion to proceed with the appeal, holding that it was the duty of Petition to file a timely notice of appeal, and he did not establish good cause for his failure to do so. View "McDaniel v. Hobbs" on Justia Law
Lewis v.State
After a jury trial, Appellant was convicted of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Appellant's sentence was enhanced for committing the crimes within 1000 feet of a park. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging (1) trial counsel had been ineffective, (2) the trial court erred in denying his motions for continuance and for appointment of new counsel, (3) he was entitled to more jail-time credit than he was given in the judgment-and-commitment order, and (4) his sentence was illegal. The circuit court denied Appellant's first, second, and fourth claims but left open the third claim pending the court's determination of how much jail-time credit Appellant was due. The Supreme Court dismissed Appellant's appeal and declared the motion Appellant filed related to the appeal moot, holding that the circuit court did not err in its judgment and that Appellant could not prevail if his appeal were allowed to proceed. View "Lewis v.State" on Justia Law
Hutcherson v. State
After a jury trial, Appellant was convicted of aggravated robbery, misdemeanor theft of property, and felony theft of property. Appellant subsequently filed a pro se petition for writ of habeas corpus, asking that the videotape that showed the robbery of a gas station, which was one of the robberies of which Appellant was convicted, should be "tested." Appellant's petition was denied. The Supreme Court dismissed Appellant's appeal and declared the motion Appellant filed in relation to the appeal moot, holding that Appellant could not prevail if his appeal were allowed to proceed, as Appellant's petition was little more than a bare allegation of innocence with no showing that there was good cause to order further scientific testing of evidence. View "Hutcherson v. State" on Justia Law
State v. Estrada
After a jury trial, Defendant was convicted of rape and first-degree sexual abuse and sentenced to life imprisonment and ten years' imprisonment, respectively. Defendant subsequently filed a petition for postconviction relief, alleging several claims of ineffective assistance of counsel. The circuit court granted Defendant a new trial based on one ground of ineffective assistance as to the rape conviction and two grounds of ineffective assistance as to the sexual-abuse conviction. The State appealed. The Supreme Court affirmed the circuit court's grant of a new trial based on ineffective assistance of counsel, holding that, based on the standard of review under Strickland v. Washington, the circuit court was not clearly erroneous in its rulings on both of Defendant's convictions. View "State v. Estrada" on Justia Law