Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se motion to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that the motion was untimely.In 1990, Defendant was convicted of burglary and theft of property. Defendant was sentenced to forty years' imprisonment and thirty years' imprisonment, respectively. In his motion to correct an illegal sentence, Defendant argued that making the thirty-year sentence part consecutive and part concurrent was illegal. The trial court denied relief. The Supreme Court affirmed, holding (1) although Defendant characterized his claim as one alleging a facially invalid sentence, it was not, and therefore, section 16-90-111 did not apply; and (2) under Ark. R. Crim. P. 37.2(c), Defendant's motion was untimely. View "Prince v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's denial of Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that this Court lacked jurisdiction over the appeal.Appellant was convicted of capital murder and first-degree battery and sentenced to life imprisonment without parole. Appellant later filed a petition to correct an illegal sentence. The circuit court denied the petition, finding that it was untimely under Ark. R. Crim. P. 37.2. Appellant appealed. The Supreme Court affirmed, holding that Appellant did not proceed in the proper circuit court, and thus, the circuit court and the Supreme Court lacked jurisdiction to address his petition. View "Grant v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying and dismissing Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to issue the writ.Appellant pleaded guilty to robbery and first-degree battery. Appellant later filed a petition for a writ of error coram nobis, asserting that his attorney and the prosecutor conducted a scheme to deceive him into entering a guilty plea. The trial court denied relief. The Supreme Court affirmed, holding that Appellant's conclusory claims in support of the allegation were not a ground for the writ and that Appellant did not meet his burden of establishing that the plea was the result of fear, duress, or threats of mob violence. View "Addison v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying relief.Defendant pleaded guilty to sexual abuse and was sentenced to 360 months' imprisonment. Defendant later filed a petition for a writ of error coram nobis alleging that the prosecutor withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that there is a reasonable probability that the judgment of conviction would not have been rendered or would have been prevented had the allegedly withheld information been disclosed; and (2) the circuit court did not err by not conducting an evidentiary hearing on the petition. View "Wood v. State" on Justia Law

The Supreme Court granted in part and denied in part Petitioner's pro se petition for writ of mandamus in which Petitioner contended that circuit court judge Dion Wilson failed to act on a petition for a previously filed writ of mandamus and amended petition for writ of mandamus, holding that Petitioner was entitled to rulings on the petitions but was not entitled to rulings granting the mandamus petitions "outright."Specifically, the Supreme Court held (1) because the circuit court had not acted on the petitions, Petitioner was entitled to an order disposing of the matter underlying the mandamus petitions; but (2) Petitioner was not entitled to relief on his request that the underlying mandamus petitions be granted outright and that he be granted a hearing. View "Rodgers v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking permission to file a writ of error coram nobis in the trial court, holding that Petitioner failed to demonstrate that he was entitled to coram nobis relief.Petitioner was convicted of two counts of felony murder and sentenced to life without parole. The judgment was affirmed on appeal. In his coram nobis petition, Petitioner raised four claims that were not cognizable in a proceeding for writ of error coram nobis. Petitioner also asserted a Brady violation, but the Court held that the Brady allegation alone was not a sufficient basis for error coram nobis relief. Petitioner also requested an attorney. The Supreme Court held that because Petitioner did not make a meritorious claim, he was not entitled to appointment of counsel. View "Linell v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing Appellant's petition for writ of habeas corpus and denied the motions subsequently filed by Appellant to amend his reply brief, holding that the circuit court did not err.In his petition, Appellant alleged (1) the judgment and commitment order was illegal on its face because it was signed by a judge that did not preside at his trial and lacked jurisdiction to enter the judgment, (2) the trial court exceeded its jurisdiction when it admitted certain evidence, and (3) the judge lacked jurisdiction because he failed to recuse himself. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims were either without merit or were not cognizable in a habeas proceeding; and (2) the circuit court was not required to appoint counsel and hold a hearing on the petition. View "Jackson v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err when it dismissed the petition without holding a hearing.In 2003, Appellant was convicted of second-degree murder and sentenced to eighty years' imprisonment. In 2019, Appellant filed a petition for writ of habeas corpus, alleging that the trial court did not have jurisdiction to convict him of second-degree murder when he was charged with first-degree murder and that there was no rational basis to support a conviction for the lesser-included offense. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding (1) the circuit court correctly dismissed the petition on the basis that Appellant had repeated claims that were unsuccessfully presented in previous habeas petitions; (2) the repetition of Appellant's previous claims represented an abuse of the writ; and (3) the circuit court was not required to hold a hearing on the petition. View "Jackson v. Kelley" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis in his criminal case, holding that the State did not violate Brady v. Maryland, 373 U.S. 83 (1963), by withholding fingerprint evidence.Petitioner was convicted of second-degree unlawful discharge of a firearm from a vehicle and possession of firearms by certain persons and was sentences as a habitual offender to an aggregate term of 360 months' imprisonment. The court of appeals affirmed. In his coram nobis petition, Petitioner raised a Brady claim, asserting that the State withheld evidence that was both material and prejudicial. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate that the State withheld material evidence. View "Oliver v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not determining that Appellant failed to state grounds demonstrating probable cause that he was being illegally detained.In his petition, Appellant argued that the general principle in Miller v. Alabama, 567 U.S. 460 (2012) that mandatory life-without-parole sentences should not apply to juveniles under the age of eighteen should apply to him because he was still young and immature. The circuit court denied relief, finding that Miller has not be applied to extend relief to offenders over the age of eighteen. The Supreme Court affirmed, holding (1) the circuit court properly denied Appellant's petition for writ of habeas corpus; and (2) Appellant did not establish that he was entitled to a hearing. View "Benton v. Kelley" on Justia Law