Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court's decision denying Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err by denying Appellant's petition.Appellant, an inmate serving several sentences, filed his petition to correct an illegal sentence alleging that the sentences imposed in his 2011 convictions and in his revocation were null and void because he was illegally arrested. The circuit court denied the petition, concluding that the petition was without merit. The Supreme Court affirmed, holding that the circuit court's judgment was not clearly erroneous. View "Mister v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus alleging that his conviction was void because his sentences exceeded the maximum statutory sentence for a Class C felony, holding that there was no error.Appellant pled guilty to, among other things, ten counts of possession and distribution of sexually explicit images of children and nineteen counts of possession and distribution of sexually explicit images of children. In his habeas corpus petition Appellant alleged that his conviction was void because his two consecutive sentences for twenty-nine counts of possessing matter depicting sexually explicit images of a child exceeded the maximum statutory sentence for a Class C felony. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's sentence of 240 months’ imprisonment each for ten counts and nineteen counts of possession of matter depicting sexually explicit images of children did not exceed the maximum penalty for those offenses. View "Osburn v. Gray" on Justia Law

The Supreme Court denied Petitioner's pro se fourth petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that the petition failed to contain facts that would support a cognizable claim for issuance of the writ.Petitioner was found guilty of residential burglary and rape and sentenced as a habitual offender to an aggregate term of 900 months' imprisonment. At issue on appeal was the denial of Petitioner's fourth pro se coram nobis petition, in which he alleged that the State falsified or failed to disclose evidence against him. The court of appeals affirmed. The Supreme Court affirmed, holding that Petitioner did not meet the criteria for granting the petition. View "Noble v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by Appellees - Arkansas Parole Board, John Felts, and Andy Shock - in Appellant's action filed pursuant to the Administrative Procedure Act (APA), Ark. Code Ann. 25-15-201 through 25-15-220, holding that Appellant failed to state a sufficient basis for judicial review under the APA.Appellant pleaded guilty to the sexual abuse of a fifteen-year-old and was sentenced to thirty years' imprisonment. Years later, the parole board denied Appellant parole for a two-year period of time. Appellant filed a petition for judicial review from the denial of his parole under the APA, alleging that Appellees failed to adhere to parole statutes and the APA, in violation of his due process rights. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it dismissed Appellant's complaint for failing to state a claim for relief pursuant to the APA. View "Wood v. Arkansas Parole Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for a copy of his trial transcript at public expense, holding that the circuit court properly concluded that Appellant had failed to demonstrate a compelling need for a copy of his trial transcript.Appellant was found guilty of two counts of aggravated robbery and one count of theft of property and sentenced as a habitual offender to life imprisonment. In his motion filed in the trial court Appellant requested copies of his trial transcript from his criminal case at public expense. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to demonstrate a compelling need for relief. View "Spearman v. State" on Justia Law

The Supreme Court granted in part and denied in part Petitioner's pro se petition for writ of mandamus for extraordinary writ for expedited consideration and/or for writ to issue relief, holding that Petitioner's request for a writ directing the court to dispose of the matter is granted.Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. At issue was Petitioner's pro se petition for writ of mandamus for extraordinary writ for expedited consideration and/or for writ to issue relief. The Supreme Court granted the writ of mandamus and denied the request for expedited consideration and writ to issue relief and denied the subsequent motion, holding (1) mandamus does lie as to the court's ministerial duty to timely act on pleadings filed; and (2) Petitioner was not entitled to relief on his remaining requests. View "Evans v. State" on Justia Law

The Supreme Court affirmed the trial court's denial and dismissal of Appellant's third pro se petition for writ of habeas corpus, holding that the trial court did not err in denying relief.In 1992, Appellant was found guilty of rape and theft of a van and sentenced to an aggregate term of thirty-five years' imprisonment. In his third pro se petition for writ of habeas corpus filed pursuant to Act 1780 of 2001, Ark. Code Ann. 16-112-201 to -208 Appellant sought scientific testing of evidence from his criminal case. The circuit court denied relief. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "Makkali v. State" on Justia Law

The Supreme Court affirmed the supplemental order of the circuit court denying Ark. R. Crim. P. 37 relief, holding that the circuit court did not err.Defendant was convicted of capital murder and sentenced to death. Defendant later sought postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding (1) Defendant was not denied the right to a fair and impartial jury; (2) the circuit court did not clearly err in denying Defendant's ineffective assistance of counsel arguments; (3) Defendant's challenges to the third death-penalty verdict form did not constitute grounds for relief under Rule 37; (4) Defendant's challenges to the verdict forms did not constitute grounds for relief; and (5) Defendant's remaining allegations of error were without merit. View "Gay v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Judge Mark Derrick challenging the constitutionality and legality of various practices concerning bond, the appointment of counsel, and the imposition and payment of fines, holding that there was no error.Appellants, who appeared before Judge Derrick, a state district court judge, as criminal defendants, were subject to court-imposed fines that they failed to pay, often resulting in jail time and additional fines. Appellants sued Judge Derrick in his official capacity, raising several challenges. The circuit court granted summary judgment in favor of Judge Derrick on all claims. The Supreme Court affirmed, holding that judicial immunity prevented this Court from granting Appellants their requested relief. View "Mahoney v. Derrick" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for declaratory judgment and mandamus relief, holding that Appellant failed to demonstrate that he was entitled to relief.Appellant was convicted of first-degree murder, aggravated robbery, and aggravated assault. After the Supreme Court remanded the case, Appellant's second trial resulted in a mistrial. Appellant then entered a negotiated guilty plea to manslaughter and robbery. In his petition for declaratory judgment and mandamus relief Appellant alleged that the Arkansas Department of Correction miscalculated his parole eligibility date and that his sentences violated the prohibition against double jeopardy and the doctrine of merger. The circuit court denied relief. The Supreme Court affirmed, holding that there was no error. View "Harmon v. Noel-Emsweller" on Justia Law