Justia Arkansas Supreme Court Opinion Summaries

Petitioner Charles Rodgers was convicted of rape and sentenced to life imprisonment. Petitioner subsequently filed a petition in the Supreme Court that sought to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and two motions that sought to supplement and amend that request with a substituted petition or additional documents. The Supreme Court denied the requests to supplement and amend the petition and the petition to reinvest jurisdiction in the trial court, holding that Petitioner did not meet his burden to state some basis that would warrant a proceeding for the writ. View "Rodgers v. State" on Justia Law

Appellant Ronald Little pled no contest to one charge of manslaughter and one charge of second-degree battery, for which he received a cumulative sentence of 240 months' incarceration. Appellant subsequently filed a verified pro se petition for postconviction relief, alleging that his trial counsel was ineffective for several reasons. Before the Supreme Court were two pro se motions filed by Appellant related to his appeal. The Supreme Court dismissed Appellant's appeal and declared the motions moot, holding that the circuit court did not clearly err in concluding that counsel's performance was not ineffective, and therefore, Appellant could not prevail if his appeal were allowed to proceed. View "Little v. State" on Justia Law

Appellant Jessie Goins was convicted by a jury of aggravated robbery and was sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a petition for writ of habeas corpus. The petition was denied by a written order. Appellant then filed a second petition for writ of habeas corpus, asserting the same grounds for the writ as he alleged in the earlier habeas petition. The petition was denied. The Supreme Court affirmed, holding (1) the circuit court did not err in determining that the claims presented in Appellant's petition were not the kind that could support habeas-corpus relief; and (2) the circuit court did not err in determining that Appellant's second point was not cognizable in a habeas-corpus petition. View "Goins v. Norris" on Justia Law

Appellant Cornelius Earl was convicted on three counts of delivery of a controlled substance and was sentenced to a total of 960 months' imprisonment. The court of appeals affirmed his convictions and sentence. Earl subsequently filed a petition for postconviction relief, alleging that his trial counsel operated under an actual conflict of interest due to counsel's simultaneous representation of Earl and his girlfriend, who also faced charges stemming from the same incident. Earl alternatively asserted that any waiver by him of the conflict was not knowing, voluntary, or intelligent. The circuit court denied the petition. Earl appealed, arguing that the trial court did not meaningfully inquire into the propriety of multiple representation. The Supreme Court affirmed, holding that because nothing in the circumstances of this case indicated that the trial court had a duty to inquire whether there was a conflict of interest, the inquiry was not insufficient, and therefore, the circuit court did not err in denying postconviction relief. View "Earl v. State" on Justia Law

In 1997, Phillip Sullivan pled guilty to theft of property and was sentenced pursuant to the Community Punishment Act. In 2011, Sullivan filed a petition to seal the record in his theft-of-property case, claiming he was entitled to have his record expunged pursuant to the Act. The circuit court denied the petition, determining that it was without jurisdiction to grant the relief. In its order, the circuit court quoted from the version of the Act in effect in 1997 instead of the 2011 version. The Supreme Court affirmed, holding (1) because Sullivan failed to object below to the application of the 2011 version of the Act and failed to raise any arguments on appeal in relation to the 1997 version, the Court could not engage in an interpretation of the 1997 version of the statute; and (2) the Court could not address the arguments that were raised by Sullivan on appeal in relation to the 2011 version of the Act because to do so would be to issue an advisory opinion on a version of the statute that had no application to the instant case. View "Sullivan v. State" on Justia Law

Petitioner Rickey Strain was convicted by a jury of first-degree murder and was sentenced to 300 months' incarceration. The court of appeals affirmed. Appellant subsequently filed a timely petition for postconviction relief, asserting, inter alia, ineffective assistance of counsel. The trial court denied the petition following an evidentiary hearing. The Supreme Court affirmed. Petitioner then filed a petition for rehearing, asserting that the Court made specific errors of law or fact in its opinion. The Supreme Court denied the petition for rehearing, holding that the opinion did not contain any errors of fact or law that would warrant granting the instant petition. View "Strain v. State" on Justia Law

Appellant James Lowe was convicted of possession of drug paraphernalia with intent to manufacture methamphetamine. Appellant subsequently filed a petition for postconviction relief, setting forth nine claims of ineffective assistance of counsel and other claims not cognizable in a petition for postconviction relief. The circuit court denied the petition. Appellant then filed a petition for writ of certiorari to complete the record and a motion for appointment of counsel. The Supreme Court denied the petition, dismissed the appeal, and declared the motion moot, holding that the trial court did not err in denying the postconviction relief petition, as Appellant did not include in facts that would demonstrate prejudice for any of the claims of ineffective assistance of counsel. View "Lowe v. State" on Justia Law

Appellant Raymond Leach was convicted of capital murder and sentenced to life in prison without parole. On appeal, Appellant claimed five points warranted reversal of his conviction. The Supreme Court affirmed, holding that the circuit court did not err (1) in denying Appellant's motion for directed verdict on capital murder, as there was sufficient evidence for the jury to support the conviction; (2) in denying Appellant's motion to suppress his custodial statement, as the statement was freely and voluntarily given; and (3) by allowing a law-enforcement officer to testify regarding his personal observation at the crime scene. The Court held that the remainder of Appellant's arguments were not preserved for appellate review. View "Leach v. State" on Justia Law

Timothy Howard was convicted by a jury of two counts of capital murder and one count of attempted capital murder. Howard was sentenced to death plus thirty years and a $15,000 fine. The Supreme Court affirmed Howard's convictions and sentences on all counts. After unsuccessfully seeking relief through several postconviction motions, Howard filed the current petition to reinvest jurisdiction in the circuit court for purposes of error coram nobis relief. The Supreme Court granted the petition in part and denied it in part, holding that Howard asserted two claims regarding the guilt phase that were appropriate for reinvesting the circuit court with jurisdiction, both of which were based on alleged Brady violations that had apparent merit. The claims were the State's failure to disclose a DNA report with handwritten notes showing potential errors made during the DNA testing of certain hairs and the State's failure to disclose a report from the Arkansas Crime Lab indicating that wood particles found on Howard's alleged work boots did not match the doors of the victims' home. The Court further granted the petition in regards to Howard's claim that mitigation evidence was withheld from him prior to trial. View "Howard v. State" on Justia Law

Following a jury trial, Appellant Danny Henington was convicted of felony rape and sentenced to thirty-six years' imprisonment. The court of appeals affirmed. Appellant timely filed a petition for postconviction relief, arguing that his trial counsel was ineffective. The circuit court denied Appellant's petition without a hearing. Appellant appealed, arguing that the circuit court erred in failing to conduct an evidentiary hearing and that the court's written findings constituted reversible error. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's petition, as (1) the recorded demonstrated that counsel did not perform deficiently, and thus the circuit court did not err in denying an evidentiary hearing; and (2) the court's written findings complied with Ark. R. Crim. P. 37.3. View "Henington v. State" on Justia Law