Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment plus fifteen years for a firearm enhancement, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the circuit court did not err by (1) admitting the victim's hearsay statements after finding they went to the victim's state of mind at the time of her death; (2) admitting an in-court identification; and (3) admitting evidence of Defendant's efforts to flee law enforcement in Texas and West Virginia as independently relevant to demonstrate a consciousness of guilt. View "Dorsey v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition for a writ of certiorari and his alternative request to recall the mandate, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. In his petition for certiorari and motion to recall the mandate, Petitioner argued that there was a defect in his criminal proceedings in that the trial judge failed to recuse himself in a posttrial matter, invalidating the judgment of conviction. The Supreme Court denied relief, holding that Petitioner's first argument was unavailing and that Petitioner did not establish the criteria that would establish extraordinary circumstances sufficient to recall the mandate. View "Rayford v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's convictions but reversed the amount of assessed costs, holding that the court costs billed to Defendant were excessive according to statute and that no other prejudicial error was present in this case.Defendant was convicted of first-degree murder, aggravated assault, and first-degree terroristic threatening. Defendant was sentenced to life imprisonment plus a fifteen-year firearm enhancement for his murder conviction. On appeal, Defendant challenged the sufficiency of the evidence as to each conviction. The Supreme Court affirmed the convictions but reversed the amount of assessed court costs, holding (1) under statute, the court costs billed to Defendant should have been $150 instead of $165; and (2) there was no prejudicial error as to Defendant's remaining allegations of error. View "Hayes v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise claims that are cognizable in coram nobis proceedings.Petitioner was found guilty of two counts of rape. In his coram nobis petition, Petitioner claimed that as a result of his mental defect he was incompetent to stand trial. The Supreme Court denied relief, holding that because Petitioner made no assertion that there was any evidence of his incompetence regarding a mental disease or defect extrinsic to the record, hidden from the defense, or unknown at the time of trial, Petitioner fell short of meeting his burden of disclosing a fact extrinsic to the record on which a writ of error coram nobis should issue. View "Smith v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of habeas corpus and petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err.Appellant, an inmate, pleaded guilty to failure to report and the related revocation in several felony cases. Appellant filed numerous pleadings, all of which the trial court denied. Appellant appealed the trial court's denial of habeas corpus and Rule 37.1 relief. The Supreme Court affirmed, holding (1) the circuit court lacked jurisdiction over Appellant's habeas corpus petition; and (2) because Appellant did not file his petition within the time limit set by Rule 37.1, the trial court properly denied postconviction relief. View "Taylor v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court convincing Defendant of first-degree murder and sentencing him to life imprisonment and a sentencing enhancement, holding that the circuit court did not err or abuse its discretion.A jury found Defendant guilty of the first-degree murder of Bianca Rainer. The Supreme Court affirmed the conviction, holding that the circuit court (1) did not err in refusing to suppress a detective's testimony about one of Defendant's custodial interviews that failed to record properly; and (2) did not abuse its discretion in admitting sixteen crime-scene and autopsy photographs of the victim over objections. View "Bennett v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellant was convicted of second-degree murder and sentenced to 300 months' imprisonment with a firearm enhancement of 180 months. In his habeas petition, Appellant alleged that the judgment of conviction did not reflect that his sentence was enhanced as a habitual offender by requiring him to serve 100 percent of his sentence, and therefore, his sentence was illegal. The circuit court denied the petition. The Supreme Court affirmed, holding that because the judgment may be corrected at any time to reflect that Appellant was not eligible for parole, Appellant failed to demonstrate that he was entitled to habeas relief on the basis that his enhanced sentence was illegal. View "Jones v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without the possibility of parole, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the conviction; (2) the circuit court did not err in admitting evidence regarding Defendant's prior bad acts under Ark. R. Crim. P. 404(b) because the evidence had independent relevance and was not unduly prejudicial; and (3) the circuit court did not err in not allowing Defendant to question a detective regarding a prior inconsistent statement made by a witness. View "Atwood v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant did not state a ground for the writ.Appellant was found guilty of first-degree murder and sentenced as a habitual offender to 600 months' imprisonment. Appellant later filed a petition for writ of habeas corpus, asserting that the judgment was void because the information was signed by a deputy prosecutor rather than the prosecuting attorney. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant did not establish a basis for the writ because Appellant's claim was not cognizable in habeas proceedings. View "Sims v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of three counts of rape, holding that there was no prejudicial error in the proceedings below.After a jury trial, Defendant was convicted of three counts of rape and sentenced to life imprisonment on each count. The Supreme Court affirmed, holding (1) the circuit court did not err when it did not grant Defendant's motion for a directed verdict; and (2) Defendant was not prejudiced and his right to a fair trial was not put in jeopardy when the circuit court allowed one of the victims to remain in the courtroom throughout the trial. View "Dominguez v. State" on Justia Law

Posted in: Criminal Law