Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.In his petition, Petitioner asserted that the prosecution withheld material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and withheld facts regarding information obtained during the police investigation. Petitioner later filed a motion asserting additional bases for issuance of the writ. The Supreme Court denied the petition and the motion, holding that Petitioner did not state sufficient allegations to satisfy issuance of the writ. View "Jones v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion for an independent action to set aside his conviction for fraud, holding that the trial court did not err in denying the motion on the basis that Defendant was precluded from seeking postconviction relief under Ark. R. Civ. P. 60(k).Defendant pleaded guilty to first-degree murder and was sentenced to life imprisonment. Defendant later filed a Rule 60(k) motion for an independent action to set aside his judgment for fraud upon the court, alleging that he did not agree to plead guilty in exchange for a life sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Rule 60 does not apply to criminal proceedings such as this one. View "Robinson v. State" on Justia Law

The Supreme Court granted Petitioner's pro se motion for rule on clerk and denied Petitioner's pro se motion for transcript, petition for writ of mandamus, and motion for appointment of counsel, holding that Petitioner was entitled to relief pursuant to Rule 2-2 of the rules of the Supreme Court.Petitioner was convicted of rape, aggravated residential burglary, and other crimes. In his motion for rule on clerk, Petitioner alleged that his counsel failed to perfect an appeal from his convictions by neglecting to lodge the record. The Supreme Court agreed, holding (1) because there was no order dismissing the appeal or otherwise relieving counsel from their obligation to perfect the appeal, counsel for Petitioner were obligated to lodge the record in the appellate court and to continue representing Petitioner; (2) because Petitioner's remedy lay in his motion for rule in clerk, his writ of mandamus is denied; and (3) Petitioner's motions either did not comply with the criminal rules of appellate procedure or were premature. View "Dominique v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for writ of habeas corpus, motion to recall mandate to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis, and joinder of claims, holding that Petitioner's claims did not establish grounds for the relief he sought.Petitioner was convicted of rape and terroristic threatening. The Supreme Court denied Petitioner's petition and motions, holding (1) Petitioner must first file his habeas corpus petition in the circuit court in the county where he was incarcerated; and (2) Petitioner did not satisfy any ground for granting a writ of coram nobis because he did not allege that there was any evidence extrinsic to the record that was hidden from the defense or that was unknown at the time of trial. View "Mitchael v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow Petitioner to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner's claim failed to establish cause to permit Petitioner to proceed in the trial court with a coram nobis petition.Petitioner was convicted of multiple drug-related offenses and sentenced to an aggregate 1848 months' imprisonment. In his coram nobis petition, Petitioner argued that the State committed a Brady violation. The Supreme Court denied the petition, holding that Petitioner failed to establish the State committed a Brady violation. View "McKinney v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of rape, holding that there was no prejudicial error below.Specifically, the Supreme Court held (1) there was substantial evidence to support the jury's verdict; (2) the circuit court did not commit reversible error in denying Defendant's rape-shield motion; (3) any alleged error in the trial court's sustaining a hearsay objection was harmless; (4) the circuit court did not err in denying Defendant's motion to suppress evidence; (5) the circuit court did not err in denying Defendant's motion to allow a prior statement into the record; (6) the circuit court did not err in overruling Defendant's objection to the prosecutor's questions to the victim; and (7) there was no prejudicial error in the failure to add a transcription of the jury-selection proceedings in the record. View "McKee v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner did not establish a Brady violation or that evidence was falsified as grounds for issuance of the writ.Petitioner was convicted of aggravated robbery and kidnapping. In his second coram nobis petition, Petitioner raised a Brady claim alleging that the State withheld crime-lab reports and conspired to manipulate DNA evidence to falsely identify him as the assailant. Petitioner's remaining claims were allegations of ineffective assistance of counsel. The Supreme Court denied relief, holding (1) Petitioner did not establish a Brady violation; (2) Petitioner did not establish that evidence was falsified; and (3) Petitioner's remaining allegations were not grounds for the writ. View "Williamson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of second-degree sexual assault and sentence of sixty months' imprisonment, holding that the victim's therapy records were protected from disclosure by the absolute psychotherapist-patient privilege in Ark. R. Evid. 503.On appeal, the court of appeals determined (1) the Arkansas privilege law did not absolutely shield the victim's therapy records, and the circuit court should have conducted an in camera review for favorable Brady evidence; and (2) the records did not satisfy Brady's materiality requirement. The Supreme Court vacated the court of appeals' judgment and affirmed Defendant's conviction, holding (1) the therapy records and communications were privileged under Rule 503; and (2) Defendant was not constitutionally entitled to disclosure of the privileged records. View "Vaughn v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's three pro se petitions for a writ of error coram nobis, holding that the circuit court did not err by not granting relief.Appellant pled guilty to four counts of first-degree sexual assault. Appellant later filed three separate petitions for error coram nobis relief. The trial court denied all three petitions. The Supreme Court affirmed, holding that even if Appellant's allegations were considered to be true, Appellant did not establish that there was a reasonable probability that the allegations would have changed the result of the proceedings. View "Hayes v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder, first-degree escape, and employment a firearm to commit the murder, holding that there was no prejudicial error.Specifically, the Supreme Court held (1) the circuit court did not err by denying Defendant's motion for directed verdict on the first-degree-murder charge; (2) Defendant was not denied assistance of counsel; (3) the circuit court did not abuse its discretion by not instructing the jury on the lesser-included offenses of second-degree murder and manslaughter; and (4) the circuit court did not abuse its discretion in excluding certain text messages that were purportedly sent to Defendant by the victim. View "Armstrong v. State" on Justia Law