Justia Arkansas Supreme Court Opinion Summaries

Appellant Mitchell Skinner entered into a negotiated plea of guilty to capital murder and was sentenced to life without parole. Appellant subsequently filed a petition for writ of habeas corpus, arguing (1) the trial court failed to comply with the rules of criminal procedure during the guilty-plea proceeding, (2) his plea was not knowingly and voluntarily entered into, and (3) his counsel rendered ineffective assistance. The circuit court dismissed the petition, ruling (1) Appellant failed to state a claim on which relief could be granted, and (2) because Appellant had previously made his claims on direct appeal and in a petition for postconviction relief, the doctrine of law-of-the-case precluded reconsideration of the issues. The Supreme Court affirmed, holding that the circuit court properly dismissed Appellant's petition because Appellant failed to state a cognizable claim, and therefore, he failed to show any basis for a finding that a habeas writ should issue.

Appellant entered a plea of guilty to first-degree murder and received a life sentence. Appellant subsequently filed a petition for postconviction relief. At the time of Appellant's conviction, Ark. R. Crim. P. 37.2(c) required that a petition claiming relief must be filed within three years of the date of commitment unless the ground for relief would render the judgment absolutely void. The circuit court denied Appellant's petition on procedural grounds as the petition was not filed within the requisite three years, and on substantive grounds as the allegations were insufficient to void the conviction. Appellant appealed, contending that the three-year period did not control because his conviction was void as a matter of law. The Supreme Court affirmed, holding that Appellant's claims were not sufficient to render his conviction absolutely void, and thus his petition, which was filed well beyond the three-year limit rule, was untimely filed.

In a dependency-neglect case, the circuit court awarded permanent custody of two children to their maternal grandmother and awarded standard visitation to their father, appellant Jamie Mahone. On appeal, Mahone contended that the circuit court erred by basing its decision on the goal of not separating siblings rather than by applying the preferred goals set forth in Ark. Code Ann. 9-27-338. Specifically, Mahone asserted that reunification with him was the first preference set forth in the statute and that, because he was fit to take his children, the circuit court erred in choosing the fifth preference listed, a fit and willing relative, on the basis of its desire not to separate the children from their half-sibling. The Supreme Court reversed, holding (1) the first statutory preference applied to Mahone, and (2) as it was not certain that the circuit court would have awarded custody to the grandmother had it applied the statutory preference afforded to parents in its best-interest analysis, a remand was necessary. Remanded.

Appellant Thernell Hundley pled guilty to capital murder and was sentenced to a life term of imprisonment without parole. Appellant subsequently filed a pro se petition to dismiss the judgment, arguing that he was seventeen years of age at the time of his conviction and that his life sentence violated, among other things, the Eighth Amendment. In support of his Eighth Amendment claim, Appellant cited as authority Graham v. Florida, in which the U.S. Supreme Court held that the Eighth Amendment prohibits the imposition of a sentence of life without parole on a juvenile offender who did not commit homicide. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that because Appellant pled guilty to a homicide offense, his sentence of life imprisonment did not violate the Eighth Amendment under Graham.

Appellant Jim Henson pled guilty to first-degree sexual assault and failure to appear. Appellant filed a petition for postconviction relief, asserting ineffective assistance of counsel. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that the circuit court did not clearly err as (1) the evidence supported the circuit court's findings that Appellant's guilty pleas were voluntarily and intelligently made; (2) the evidence showed that Appellant's guilty pleas were made on the advice of competent counsel; (3) Appellant failed to show there was a reasonable probability that, had a mental evaluation been requested by counsel on the day Appellant pled guilty, the outcome of the proceeding would have been different; and (4) Appellant did not demonstrate prejudice by his sentence.

A jury convicted Levonia Gray of first-degree battery and first-degree terroristic threatening. The court of appeals affirmed. Appellant then filed a petition for postconviction relief, claiming that his counsel was ineffective for failing to move for a directed verdict and that counsel's failure to address whether the victim was battered by means of a firearm in a directed-verdict motion resulted in prejudice to him. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that the circuit court's denial of relief was not clearly erroneous because (1) Appellant failed to demonstrate that he was prejudiced by counsel's failure to move for a directed verdict and failed to establish a reasonable probability that the circuit court would have acquitted him if counsel had presented the "by means of a firearm" argument to the court in a motion for directed verdict, and (2) therefore, Appellant failed to satisfy the second prong of Strickland v. Washington in his argument that his trial counsel was ineffective.

A jury found Appellant David Fuson guilty of computer child pornography, for which Appellant was sentenced to twenty years' incarceration. On appeal, Appellant contended that the circuit court erred in denying his motions to suppress his custodial statements and to exclude the evidence seized in search of his vehicle. The Supreme Court affirmed Appellant's conviction, holding (1) the circuit court did not clearly err in denying the motion to suppress Appellant's custodial statements as he waived the suppression issue by testifying at trial and adopting as true the material portions of the challenged pretrial statement, and (2) because the circuit court based its decision regarding Appellant's argument concerning the denial of the motion to suppress evidence on two independent grounds and Appellant challenged only one ground on appeal, the merits of Appellant's argument could not be addressed on appeal.

Appellant Robert Davis was convicted of capital murder and aggravated robbery and was sentenced to life imprisonment without parole. On appeal, Appellant contended that the admission of a witness's out-of-court statement deprived him of his Sixth Amendment right to confront witnesses. Specifically, Appellant asserted that because the witness was unable to remember her out-of-court statement, she was constructively unavailable as a witness. The Supreme Court found no error and affirmed, holding that the fact that the witness was unable to recall the details of her out-of-court statement on direct examination was of no consequence where Davis declined the opportunity to cross-examine her.

Appellant Gregory Cook pled guilty to capital murder and was sentenced to a term of life imprisonment without parole. Appellant filed a petition for writ of habeas corpus, which the circuit court denied, finding that (1) Appellant's allegations failed to demonstrate that the circuit court lacked jurisdiction or that his commitment order was invalid on its face, and (2) Appellant's claim that he was denied a transcript of his plea hearing was not one cognizable in a habeas proceeding. The Supreme Court affirmed, holding (1) Appellant's objections to the form or sufficiency of an indictment or information should have been raised in the court below, and (2) Appellant's allegations that the judicial officer did not sign his arrest warrant, that his plea was not voluntarily made, and that it was a miscarriage of justice for him to be denied a copy of the transcript of his plea-agreement hearing were not issues cognizable in a habeas proceeding.

Appellant Louis Butler was convicted of capital murder by unlawful discharge of a firearm from a vehicle. During trial, the circuit court rejected Butler's proffered instruction on manslaughter based on imperfect self-defense and manslaughter committed under extreme emotional disturbance because the court did not find "a scintilla" of evidence to support any form of manslaughter other than the question of whether Butler recklessly caused the victim's death. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in refusing to give the proffered instruction because there was no evidence to support the other forms of manslaughter and, therefore, no rational basis on which to give the proffered instruction.