Justia Arkansas Supreme Court Opinion Summaries

Appellant Vincent Webb was convicted of the kidnapping and rape of a twelve-year-old girl and was sentenced as a habitual offender to concurrent sentences of forty years and life imprisonment. Appellant appealed, contending that the circuit court erred by refusing his request to instruct the jury that second-degree sexual assault was a lesser-included offense of rape. The Supreme Court affirmed the circuit court's refusal of Appellant's proffered jury instruction, holding that, consistent with Joyner v. State, the circuit court correctly determined that second-degree sexual assault requires proof of additional elements that rape does not, and therefore, it is not a lesser offense included in rape. View "Webb v. State" on Justia Law

Petitioner Timothy Davis entered a plea of guilty to capital murder and was sentenced to life imprisonment without parole. Davis subsequently filed a petition for postconviction relief, which the trial court denied on its merits. Petitioner did not perfect an appeal from the trial court's order denying relief and sought leave from the Supreme Court to proceed with a belated appeal. The Court denied the motion, holding that because Petitioner's only ground for granting a belated appeal was that he timely filed a notice of appeal and he did not substantiate that claim, Petitioner failed to demonstrate that he should be permitted to proceed with a belated appeal of the trial court's order. View "Timothy. v. State" on Justia Law

Appellant Terrell Davis pleaded guilty to multiple felony offenses. Ninety-five days after the judgments were entered-of-record, Appellant filed in the trial court a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The petition was denied on the ground that it was not timely filed under the rule. Appellant appealed. Before the Supreme Court was a motion filed by Appellant related to his appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant's petition was untimely pursuant to Ark. R. Crim. P. 37.2(c), which provides that a petition under the rule must be filed within ninety days of the date the judgment was entered if the petitioner entered a plea of guilty. View "Terrell v. State" on Justia Law

In two separate cases, Appellant Brian Heard entered negotiated pleas to a total of four counts of delivery of a controlled substance as to various drugs and that eleven other charges were nolle prossed. Appellant timely filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, which the trial court denied. Appellant appealed, contending that his guilty plea was coerced by trial counsel and that trial counsel was ineffective. The Supreme Court affirmed, holding (1) Appellant did not provide credible evidence to support his claim that he was coerced and would not have entered a guilty plea had counsel provided effective assistance; and (2) Appellant did not meet his burden to show prejudice from any deficient performance on the part of trial counsel. View "Heard v. State" on Justia Law

Petitioner Belynda Goff was found guilty by a jury of first-degree murder in the death of her husband and was sentenced to life imprisonment. Petitioner subsequently requested that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In support of her petition, Petitioner contended that her defense at the time of trial was not made aware of three documents Petitioner recently discovered. Petitioner argued that the documents offered proof that someone else murdered her husband and that the State violated the requirements of Brady v. Maryland by withholding the documents from the defense. The Supreme Court denied the writ, holding that Petitioner did not show there was a reasonable probability that the outcome of the trial would have been different had any of the documents at issue been available to the defense. View "Goff v. State" on Justia Law

Appellant Tyrone Ellis was convicted of first-degree murder and felon in possession of a firearm and was sentenced to life in prison. Ellis appealed, contending (1) the evidence was insufficient to support his conviction, and (2) the prosecuting attorney improperly inquired into the nature of Ellis's prior felony convictions during cross-examination. The Supreme Court affirmed the convictions, holding (1) viewing the evidence on appeal in the light most favorable to the State, there was substantial evidence to support Ellis's conviction for first-degree murder and felon in possession of a firearm; and (2) the trial court did not abuse its discretion by allowing into admission Ellis's prior crimes for impeachment purposes where it was clear from the record that the probative value of the evidence outweighed the potential for unfair prejudice. View "Ellis v. State" on Justia Law

Appellant Joe Simmons was convicted on drug-related charges and failure to appear. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition. Appellant appealed, contending that the trial court erred in finding that trial counsel was not ineffective for failing to object to the restraints used on Appellant during his jury trial or for failing to request an instruction ordering the jury not to consider those restraints in their deliberations. The Supreme Court affirmed, holding that there was no clear error in the trial court's findings and its conclusion that trial counsel was not ineffective.

Appellant Anthony Reed was found guilty by a jury of aggravated robbery, theft of property, and two counts of second-degree battery. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus. The circuit court dismissed the petition. Appellant appealed. Before the Supreme Court was Appellant's motion to correct the record. The Court dismissed the appeal and declared the motion moot, holding that Appellant could not prevail on appeal of the order denying his petition where he failed to state cognizable claims and did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue.

Following a jury trial, Appellant Vadarian Meadows was found guilty of capital murder, residential burglary, and theft of property. For reversal, Appellant contended (1) the evidence was not sufficient to support his convictions because the State failed to corroborate his confession and the testimony of an accomplice, and (2) the capital murder and first-degree murder statutes were unconstitutionally vague because they were substantially identical and resulted in jury confusion. The Supreme Court affirmed, holding (1) because the evidence showed that the corroboration requirements were met, there was substantial evidence to support Appellant's convictions; and (2) Appellant's second contention was not preserved for appeal.

Appellant Routy Abernathy was convicted of two counts of rape. Appellant subsequently filed a pro se petition for postconviction relief, raising a number of claims of ineffective assistance of counsel. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in finding (1) trial counsel did not err by failing to investigate, consult with, or call a medical expert; (2) Appellant was not prejudiced from counsel's remarks during his opening statement; (3) Appellant did not demonstrate that he was sufficiently prejudiced by counsel's error in failing to object to a witness's testimony that she believed one victim's allegations to meet his burden of proof; and (4) a victim's claims about sexual abuse by her grandfather would not have been admissible and, therefore, counsel was not ineffective for failing to seek a ruling on introduction of the evidence.