Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
King v. State
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner failed to allege cognizable grounds for the issuance of a writ of error coram nobis.Petitioner was convicted of first-degree murder and sentenced to forty years in prison. The case was reversed, and therefore, the prosecutor added a habitual-offender charge to the information. After a retrial, the jury convicted Petitioner of first-degree murder and sentenced him to sixty years' imprisonment due to his habitual-offender status. Petitioner filed a petition for writ of error coram nobis, alleging prosecutorial misconduct and that his sentence was illegal. The Supreme Court denied the petition, holding that Petitioner's claims did not fall within the purview of coram nobis relief. View "King v. State" on Justia Law
Posted in:
Criminal Law
Riley v. State
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for postconviction relief pursuant to Ark. R. Crim. P. 37, holding that the court did not err by denying the petition without a hearing.Appellant was convicted of murder in the first degree and sentenced to life imprisonment. In his Rule 37 petition, Appellant alleged that his trial counsel was ineffective for failing to request an instruction on second-degree murder. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err in summarily denying Appellant's Rule 37 petition. View "Riley v. State" on Justia Law
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Criminal Law
Davis v. Kelley
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
Posted in:
Criminal Law, Government & Administrative Law
Kolb v. State
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
Anderson v. Payne
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
Hussey v. State
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
Commons v. Kelley
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
Flow v. State
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
Anderson v. Payne
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
Hill v. State
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