Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, holding that there was no error in the circuit court's order denying Rule 37 relief.Defendant was convicted of capital murder and sentenced to death. Numerous proceedings followed. This appeal concerned Defendant's petition for postconviction relief. The circuit court entered an order denying Defendant relief on every claim. The Supreme Court affirmed, holding (1) there was no deficient performance by trial counsel under the Strickland standard; (2) the circuit court did not err in denying relief on the issue of Defendant's competency to stand trial; (3) Defendant's claim of juror misconduct was not cognizable in this postconviction proceeding; and (4) Defendant's remaining claims did not warrant reversal of his convictions. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court refusing to instruct the jury on two instructions proffered by Defendant at a resentencing hearing, holding that the circuit court did not err or abuse its discretion.Defendant, who was seventeen years old at the time of the offense, pled guilty to capital murder. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, it was determined that Defendant should be resentenced by a jury. After a resentencing hearing, the jury imposed a sentence of life in prison. Defendant appealed, challenging the circuit court's rejection of two jury forms proffered by Defendant. The Supreme Court affirmed, holding that the circuit court did not err in denying the requested jury instructions. View "Grubbs v. State" on Justia Law

The Supreme Court affirmed the circuit court's order denying Defendant's petition for scientific testing of evidence, holding that the circuit court's decision denying the petition was not clearly erroneous.Defendant was convicted of rape, aggravated assault, and related convictions. Defendant later filed a petition under Ark. Code. Ann. 16-112-201 through 208 seeking further scientific testing of the vaginal swab collected from the victim. The trial court denied the petition. The Supreme Court affirmed, holding (1) where Ark. Code. Ann. 16-112-201 through 208 is the codification of Act 1780 of 2001 the circuit court did not err in applying Act 1780; (2) the circuit court did not err in denying Defendant's petition on the merits; and (3) the circuit court was not required to hold an evidentiary hearing on the petition. View "Rayfield v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no basis for the writ.Appellant pleaded guilty to capital murder, attempted capital murder, and unlawful discharge of a firearm. Appellant later filed his petition for writ of habeas corpus, arguing that the State lacked jurisdiction to try him for the offenses because they were referred to as "international terrorism" committed by a "foreign terrorist organization" and that he was not afforded effective assistance of counsel. The Supreme Court affirmed, holding (1) the fact that Appellant's conduct could have been charged as a crime under a federal statute did not prohibit the State from trying him in state court; and (2) Appellant's claims of ineffective assistance of counsel were not cognizable as a ground for the writ. View "Muhammad v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's habeas corpus petition challenging a 1983 circuit court judgment reflecting Appellant's guilty plea to first-degree murder and the life sentence imposed, holding that Appellant did not demonstrate clear error by the circuit court.In his petition, Appellant alleged that he was actually innocent of the charge because he had been unaware when he entered his plea that he had a viable defense of justification and that trial counsel was ineffective for failing to investigate and develop a justification defense. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden of demonstrating a basis for the writ to issue. View "Crockett v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to proceed in forma pauperis after seeking judicial review of Arkansas Department of Correction disciplinary proceedings under the Administrative Procedure Act, holding that Appellant failed to allege a basis for judicial review.Appellant, an inmate at the ADC, argued that he was prevented from presenting evidence and calling witnesses at his disciplinary hearing in violation of ADC policy and that his due process rights were violated thereby. The circuit court denied Appellant's petition to proceed as a pauper. The Supreme Court affirmed, holding that the circuit court properly denied Appellant's petition to proceed in forma pauperis because Appellant's underlying petition clearly failed to state a colorable cause of action. View "Perry v. State" on Justia Law

The Supreme Court affirmed the denial by the trial court of Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err by denying Appellant's numerous claims of ineffective assistance of counsel and that the trial court properly denied the petition without an evidentiary hearing.Appellant was convicted of capital murder, aggravated robbery, and kidnapping. The Supreme Court affirmed the convictions. Appellant later filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that the trial court did not err in denying postconviction relief and that Appellant was not entitled to an evidentiary hearing. View "Dennis v. State" 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 and audita querela in his criminal case, holding that Petitioner's claims did not establish a ground for the writ.In his petition, Petitioner argued that the trial court erred in failing to apply the criminal code section that was in effect at the time was committed and that the prosecutor committed a Brady violation by withholding a medical report pertaining to an examination of the victim. The Supreme Court denied relief, holding that the existence of medical records that described the absence of corroborating physical evidence was known to defense counsel and that, even if the prosecutor had withheld this medical report, the outcome of the trial would not have changed as a result. View "Tolston v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1, in which he would challenge a judgment reflecting his sentence of life imprisonment without parole for capital murder, holding that Petitioner failed to set out a meritorious basis for relief under Rule 37.1.The judgment challenged by Petitioner was entered in 1978. In his petition, Petitioner alleged seven bases for grounds for Rule 37 relief, all framed as claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner failed to set forth meritorious grounds for postconviction relief under the Rule that may be included in the proposed petition. Therefore, the Court held, there was no need to reinvest jurisdiction in the trial court. View "Hallman v. State" on Justia Law

The Supreme Court affirmed the circuit court's dismissal of Plaintiff's complaint filed against Arkansas prison officials under the Arkansas Civil Rights Act and state tort law for allegedly depriving him of a nutritionally adequate diet safe for consumption but reversed the circuit court's imposition of a strike for the dismissal of the underlying action, holding that dismissal was warranted but the strike was not.In dismissing the complaint, the circuit court concluded that Plaintiff's claims were barred by sovereign and statutory immunity and failed to state facts upon which relief could be granted. The court also issued a strike under Ark. Code Ann. 16-68-607. The Supreme Court affirmed in part and reversed in part, holding (1) because Plaintiff's allegations failed to establish a constitutional violation Plaintiff failed to surmount sovereign and statutory immunity; and (2) the strike was unwarranted. View "Harmon v. Payne" on Justia Law