Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Millsap v. Payne
The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that the grounds raised in Appellant's petition were not grounds for habeas relief.Appellant pleaded guilty to capital murder, first-degree terroristic threatening, and second-degree battery. Appellant later petitioned for a writ of habeas corpus. The circuit court denied relief, concluding that none of the allegations were cognizable in a habeas proceeding. The Supreme Court affirmed, holding that the circuit court did not err in denying habeas relief on Appellant's claims. View "Millsap v. Payne" on Justia Law
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Criminal Law
Ward v. State
The Supreme Court affirmed the circuit court's denial of Appellant's petition for writ of error coram nobis, holding that the circuit court did not abuse its discretion when it treated the petition as an untimely Rule 37.1 petition and denied it because the grounds raised in the petition were distinctly covered by that Rule.Appellant pleaded guilty to several offenses and was sentenced to an aggregate term of 300 months' imprisonment. In his coram nobis petition, Appellant argued that his counsel conspired with the prosecutor to mislead him with respect to the sentences he received for his guilty pleas and that his trial counsel acted in bad faith. The circuit court treated the petition as an untimely Rule 37.1 and denied it. The Supreme Court affirmed, holding that the circuit court's ruling that Defendant's allegations should have been raised in a timely petition under Rule 37.1 was a correct statement of law. View "Ward v. State" on Justia Law
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Criminal Law
In Response To The COVID-19 Pandemic
Here, the Supreme Court announced new protocols to maintain the safety of jurors, litigants, attorneys, court personnel and the public in light of the ongoing COVID-19 pandemic. The Court suspended until January 15, 2021 jury trials that have not begun. The Court, however, urged that judges continue to move cases forward, either through the use of technology by virtual or telephonic hearings or through in-person hearings that meet the Arkansas Department of Health's criteria for safe gatherings. The Court held that any delay for speedy-trial purposes due to precautions against the COVID-19 pandemic shall presumptively constitute good cause under Ark. R. Crim. P. 28.3(h) and shall constitute an excluded period for speedy-trial purposes. View "In Response To The COVID-19 Pandemic" on Justia Law
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Criminal Law, Health Law
Russell v. Payne
The Supreme Court affirmed the circuit court's denial of Petitioner's pro se petition for writ of habeas corpus, holding that the chief justice had the constitutional authority to appoint a special judge, who had the jurisdiction and authority to preside over Petitioner's case.Two days before Petitioner's scheduled trial, Chief Justice Hannah appointed Honorable Ted Capeheart to preside in the place of an elected circuit court judge who had suddenly fallen ill. Twice, Petitioner filed habeas petitions alleging that Judge Capeheart lacked authority to preside over his case. The circuit court denied both petitions. The Supreme Court affirmed, holding that the Chief Justice had the constitutional authority to appoint Judge Capeheart, who consequently had the jurisdiction and authority to preside over Petitioner's case. View "Russell v. Payne" on Justia Law
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Criminal Law
Waller v. State
The Supreme Court affirmed the order of the circuit court denying Petitioner's claim for habeas relief but remanded the matter for resentencing, holding that Petitioner's sentence exceeded the statutory maximum for his offenses.In his pro se petition for writ of habeas corpus Petitioner alleged that his convictions for arson and first-degree battery are void because he did not plead guilty to either offense and that his sentence for first-degree murder exceeded the length provided in the sentencing guidelines. The circuit court denied the petition. The Supreme Court affirmed in part and remanded in part, holding (1) Petitioner's claims failed to demonstrate that he was illegally detained; but (2) the suspended imposition of sentences in connection with Petitioner's convictions for first-degree murder and battery exceeded the statutory maximum for the offenses, and therefore, resentencing was necessary. View "Waller v. State" on Justia Law
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Criminal Law
Rabion v. Kelley
The Supreme Court affirmed the denial of Appellant's pro se petition for writ of habeas corpus, holding that there were no grounds stated on which a writ of habeas corpus could be issued.Defendant was convicted of two counts of negligent homicide, leaving the scene of an accident involving injury or death, driving on a suspended license, and driving while intoxicated. Defendant filed a petition for a writ of habeas corpus, raising several allegations. The Supreme Court found that Defendant's allegations did not establish probable cause for issuance of the writ. The Supreme Court affirmed, holding that Defendant was not entitled to issuance of the writ. View "Rabion v. Kelley" on Justia Law
Posted in:
Criminal Law
Combs v. State
The Supreme Court affirmed Defendant's conviction of capital murder, holding that the trial court did not err when it did not bring jurors into open court after they posed a question during deliberations.Defendant was convicted of capital murder and sentenced to life imprisonment without parole. For his sole point on appeal, Defendant argued that the trial court erred when it did not bring the jurors into open court after they posed a question during deliberations. The State conceded that the court violated Ark. Code Ann. 16-89-125(e) by not bringing the jury into open court when it asked a question. The Supreme Court held that because there was no risk of misinformation being communicated to the jury the State met its burden of overcoming the presumption of prejudice. View "Combs v. State" on Justia Law
Posted in:
Criminal Law
Flow v. State
The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se petition for a writ of error coram nobis, holding that the trial court did not abuse its discretion in denying relief.Defendant pleaded guilty pursuant to North Carolina v. Alford, 400 U.S. 25 (1977), to second-degree sexual assault. In his coram nobis petition, Defendant argued that his guilty plea was coerced. The trial court denied issuance of the writ. The Supreme Court denied relief, holding that the trial court did not clearly err when it gave greater weight to the testimony of Defendant's counsel and did not abuse its discretion when it denied Defendant's petition for coram nobis relief. View "Flow v. State" on Justia Law
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Criminal Law
Collins v. State
The Supreme Court affirmed Defendant's convictions, holding that no prejudicial error occurred during the proceedings below.Defendant was convicted of capital murder and aggravated assault. On appeal, Defendant argued that the circuit court erred in denying his motion for directed verdict and in admitting autopsy photographs after he offered to stipulate the cause of death. The Supreme Court affirmed, holding (1) substantial evidence supported Defendant's conviction; and (2) the circuit court did not abuse its discretion by admitting the autopsy photographs to aid the jury in understanding the nature and degree of the injuries the victims sustained and corroborated witness testimony. The Supreme Court remanded the case to the circuit court with directions to correct two clerical errors found in the sentencing order. View "Collins v. State" on Justia Law
Posted in:
Criminal Law
Jones v. Professional Background Screening Ass’n
The Supreme Court affirmed the order of the circuit court granting summary judgment to Professional Background Screening Association, Inc. (PBSA) on PBSA's claim pursuant to the Arkansas Freedom of Information Act (FOIA) and partial summary judgment to Jennifer Jones, the Clerk of the District Court of Benton County, Arkansas, Bentonville Division, holding that the circuit court did not err.PBSA, a nonprofit trade association, filed a complaint against Jones alleging that Jones erred in applying Arkansas Supreme Court Administrative Order Number 19 to PBSA members who request court records to perform background checks in a manner that violated their right to access court records and, instead, PBSA members' requests for court records are governed by the Arkansas Freedom of Information Act. The circuit court granted partial summary judgment in favor of PBSA on its FOIA claim and granted Jones's motion for summary judgment on PBSA's claims alleging that Order 19, as applied by Jones, violated PBSA members' right to access court records under the First Amendment and/or federal common law. The Supreme Court affirmed, holding that the circuit court did not err. View "Jones v. Professional Background Screening Ass'n" on Justia Law
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Criminal Law, Labor & Employment Law