Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment 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 correctly denied the petition as timely.Appellant was convicted of three counts of capital murder, one count of attempted rape, and one count of residential burglary. The circuit court sentenced Appellant to 140 years' imprisonment. Appellant later filed a petition to correct an illegal sentence, which was denied. The Supreme Court affirmed, holding that the circuit court did not clearly err by denying Appellant's petition as untimely under Ark. R. Crim. P. 37.2(c). View "Dirickson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of rape, second-degree sexual assault, and third-degree domestic battery, holding that the circuit court did not err or abuse its discretion.On appeal, Defendant argued that the circuit court erred by admitting as hearsay a journal entry, list, and letter written by the victim and abused its discretion by admitting evidence of his suicide attempt during his arrest. The Supreme Court affirmed, holding (1) any error resulting the admission of the victim's writings was harmless; and (2) the circuit court did not abuse its discretion in admitting evidence of suicide threats made during Defendant's arrest. View "Adams v. State" on Justia Law

The Supreme Court dismissed this appeal from the denial of Appellant's pro se motion to enforce his plea agreement, holding that Appellant's motion to enforce the plea agreement represented an untimely postconviction motion, and therefore, Appellant's notice of appeal was untimely.Appellant pled guilty to two counts of first-degree murder and was sentenced to forty-five years' imprisonment. In his motion to enforce the plea agreement, Appellant argued that the sentence he received was not the sentence included in the plea agreement. The circuit court denied the motion. The Supreme Court dismissed Appellant's appeal, holding that both Appellant's motion to enforce the plea agreement and his notice of appeal were untimely, and therefore, neither the circuit court nor the Supreme Court had authority to grant the relief sought. View "Manuel v. State" on Justia Law

The Supreme Court denied the State's petition for a writ of certiorari to the circuit court's order granting a mistrial as to both the guilt and penalty phases of Defendant's capital murder trial when the event precipitating the mistrial occurred after the jury found Defendant guilty, holding that the circuit court correctly determined that the unique circumstances in this case required a mistrial as to both the guilt and penalty phases of the trial.After a retrial, a jury convicted Defendant of capital murder and first-degree battery. During the penalty phase of trial, the State's witness lunged toward Defendant in an apparent effort to assault him. After the jury left the courtroom, Defendant's counsel moved for a mistrial of the sentencing proceeding. The circuit court declared a mistrial as to both the guilt and the penalty phases of the trial. The State filed a petition for writ of certiorari seeking an order directing the circuit court to preserve the guilty verdict and conduct a new sentencing hearing only. The Supreme Court denied the petition, holding that the circuit court did not err or exceed its jurisdiction in declaring a mistrial with respect to the guilt phase of the trial. View "State v. Torres" on Justia Law

The Supreme Court affirmed Defendant's conviction for second-degree murder and sentence of life imprisonment but reversed the additional ten years added to the sentence for a firearm enhancement, holding that Defendant's ten-year sentence under Ark. Code Ann. 16-90-121 was illegal.Specifically, the Supreme Court held (1) there was sufficient evidence to support Defendant's conviction because the State met its burden of negating Defendant's justification defense; (2) the trial court did not abuse its discretion by permitting the State to introduce evidence about Defendant's gang affiliation; (3) the trial court abused its discretion in admitting certain hearsay statements attributed to the decedent as dying declarations; and (4) the trial court illegally added ten years to Gentry’s life sentence under section 16-90-121. View "Gentry v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant's claim was not cognizable in habeas proceedings.In three separate cases, Appellant was convicted of three counts of aggravated robbery, two counts of a terroristic act, rape and aggravated robbery. Appellant's current habeas petition challenged all three convictions based on defective informations. The circuit court denied habeas relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claim for habeas relief as not cognizable. View "Benson v. Payne" on Justia Law

The Supreme Court affirmed the circuit court's order denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of first-degree murder and committing a terroristic act. The Supreme Court affirmed. In his habeas petition, Appellant argued that the first-degree murder conviction and the conviction for a terroristic act constituted multiple punishments for a single action, in violation of double jeopardy protections. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant did not meet his burden of establishing that his double jeopardy claim was cognizable in a proceeding for a writ of habeas corpus. View "Starling v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court's denial of Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that Petitioner did not allege or demonstrate in this appeal that the imposed sentences were facially illegal.Petitioner challenged the amended sentence imposed for theft of property, asserting that the property stolen did not exceed $1,000, and therefore, his sentence was excessive. The circuit court summarily denied the petition. The Supreme Court affirmed, holding that Petitioner's petition to correct the sentences imposed in the amended sentencing order was untimely and did not include a valid claim for relief under section 16-90-111. View "Green v. State" on Justia Law

The Supreme Court denied Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claim has been raised in previous petitions and rejected by this Court.Petitioner was convicted of residential burglary, first-degree battery, and aggravated robbery and sentenced to an aggregate term of 480 months' imprisonment. In his third coram nobis petition, Petitioner reasserted his claim that he was deprived of counsel during his criminal trial because his trial counsel's license was suspended at the time of trial. The Supreme Court denied the petition, holding that the petition was an abuse of the writ. View "Washington v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder, for which he was sentenced to life imprisonment, holding that there was no prejudicial error in the proceedings below.The victim in this case died two hours after Defendant threw a cup of gasoline on him, lit a cigarette lighter, and ignited the victim's upper torso, arms, and face. On appeal, Defendant argued that there was insufficient evidence to support the first-degree murder conviction because he did not "cause" the victim's death. The Supreme Court disagreed, holding that the State presented sufficient evidence for the jury to conclude that Defendant caused the victim's death. View "Brown v. State" on Justia Law