Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for a writ of mandamus with prejudice under Ark. R. Civ. P. 12(b)(6), holding that the circuit court did not abuse its discretion.Appellant was convicted of first degree murder and sentenced to life imprisonment. In 2010, Appellant submitted a request to the Arkansas State Crime Laboratory regarding DNA testing. The circuit court ordered the crime lab to release the information. When the file arrived at the prison, it was confiscated by prison officials based on their determination that it contained contraband. In 2019, Appellant filed a petition for writ of mandamus and complaint for conversion seeking to compel Appellees to release his crime lab file and monetary damages for conversion. The circuit court dismissed the case with prejudice and issued a strike. The Supreme Court affirmed, holding that the circuit court correctly dismissed Appellant's petition for writ of mandamus and complaint for conversion on the ground that Appellant had already obtained the crime lab file and that Appellant failed to state a claim upon which relief could be granted. View "Davis v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for a directed verdict, holding that the circuit court did not err in denying the motion.After a jury trial, Appellant was convicted of possession of methamphetamine and drug paraphernalia. On appeal, Appellant argued that the circuit court erred in denying her motion for a directed verdict because the State failed to prove that she possessed a "usable amount" of methamphetamine. The Supreme Court affirmed, holding that the circuit court properly denied Appellant's motion for a directed verdict. View "Kolb v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's pro se motion to recall the mandate issued by the Supreme Court on direct appeal, his petition for a writ of habeas corpus, and his motion for joinder of claims, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment. The Supreme Court affirmed. In his motion to recall the mandate, Petitioner challenged the sufficiency of the evidence supporting his conviction and also brought a Brady claim. The Supreme Court denied relief, holding (1) Petitioner did not establish extraordinary circumstances sufficient to recall the mandate; (2) Petitioner must file his writ of habeas corpus in the circuit court; and (3) Petitioner did not establish that he was entitled to joinder of claims. View "Anderson v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus seeking scientific testing of evidence from his 1996 criminal case, holding that the circuit court did not err.In 1996, Appellant was convicted of capital murder and sentenced to life imprisonment. In 2012, Defendant filed a pro se petition for writ of habeas corpus pursuant to Act 1780, asserting that he was actually innocent of the murder and seeking DNA testing on a red shirt. The circuit court denied the petition. In 2020, Appellant filed a motion to file a second or successive petition for good cause seeking scientific testing pursuant o 16-112-201 through 16-112-208. The circuit court denied the petition as successive. The Supreme Court affirmed, holding that Appellant failed to establish that additional testing would significantly advance his claim of innocence. View "Hussey v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's petition to proceed in forma paupers in connection with a petition for a writ of habeas corpus, holding that the circuit court correctly determined that Appellant failed to state a colorable cause of action.Appellant was convicted of three counts of unlawful discharge of a vehicle and was sentenced as a habitual offender to seventy-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus seeking relief based on insufficient evidence supporting a firearm enhancement and an alleged double jeopardy violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the petition clearly failed to allege a colorable cause of action. View "Commons v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not err in denying the petition.Appellant pled guilty to two counts of second-degree sexual assault and sentenced to 300 months' imprisonment. Appellant filed a motion to correct an illegal sentence, arguing that the sentencing order was illegal on its face because the prosecutor made a notation that Appellant was not eligible for parole pursuant to Ark. Code Ann. 16-93-609. The circuit court denied the motion. The Supreme Court affirmed, holding that section 16-93-609 applied to Appellant's conviction and that Appellant failed to demonstrate that his sentence were illegal. View "Flow v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the circuit court's denial of Appellant's petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition and in finding of an abuse of the writ.Appellant filed multiple postconviction actions challenging his sentence. Less than thirty days after the Supreme Court affirmed the order of the circuit court denying Appellant's second pro se petition for writ of habeas corpus Appellant filed the instant pro se petition for writ of habeas corpus. The circuit court dismissed the petition and found an abuse of the writ. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied and dismissed Appellant's habeas petition. View "Anderson v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the circuit court's dismissal of Appellant's petition for ineffective assistance of counsel filed under Ark. R. Crim. P. 37, holding that Appellant was not entitled to relief.Appellant was convicted of aggravated residential burglary and sentenced to life in prison. In his Rule 37 postconviction petition, Appellant claimed that his trial counsel was ineffective on ten grounds. The circuit court denied the petition after holding a hearing. The Supreme Court affirmed, holding that Appellant was provided constitutionally effective assistance of counsel, and therefore, his petition for postconviction relief failed. View "Hill v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree murder, attempted first-degree murder, aggravated assault, and committing first-degree murder in the presence of a child, holding that substantial evidence supported the convictions.On appeal, Defendant challenged the sufficiency of the evidence supporting his first-degree murder and attempted first-degree murder convictions. The Supreme Court affirmed, holding (1) the State presented substantial evidence of the requisite mental state for first-degree murder; (2) substantial evidence supported Defendant's conviction for attempted first-degree murder; and (3) after examining the record, no prejudicial error has been found. View "Collins v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus filed pursuant Ark. Code Ann. 16-112-101 to -123, holding that the circuit court did not err.Appellant was convicted of four counts of rape and sentenced to 480 months' imprisonment. Appellant later filed the pro se petition for writ of habeas corpus that was the subject of this appeal, making several claims. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for the writ to issue. View "Jones v. Payne" on Justia Law

Posted in: Criminal Law