Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis, holding that Petitioner's claims were not cognizable in coram nobis proceedings.In his petition, Petitioner alleged that prejudicial testimony provided by the State's expert witness was admitted at trial without objection from counsel or an admonishment from the trial court and that the admission of this testimony deprived him of due process. The Supreme Court denied the petition, holding that there was no error in the admission of the allegedly prejudicial testimony, and therefore, Petitioner failed to allege a due process violation that would come within the purview of coram nobis relief. View "Henington v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of error coram nobis, holding that Appellant did not show an abuse of discretion in the denial of the writ.In 1979, Appellant was convicted of capital felony murder. After the Supreme Court gave Appellant leave to proceed with a coram nobis petition, Appellant filed his petition, alleging a violation of Brady v. Maryland, 373 U.S. 83 (1963). The trial court determined that no Brady violation had occurred and declined to issue the writ. On appeal, Appellant claimed that the trial court failed to conduct a proper analysis when it did not treat the admission of certain evidence as structural error and failed to apply the law of the case doctrine. The Supreme Court affirmed, holding that the error in this case was not structural and that the court was correct in its analysis. View "Pitts v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking permission to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1 in which Petitioner argued that he was entitled to collaterally attack his conviction and alternatively requesting that the Supreme Court recall the mandate for his two convictions, holding that Petitioner did not state a claim for relief.Petitioner argued that he was entitled to collaterally attack his conviction because the Arkansas statute under which his arrest warrants were issued was declared unconstitutional under Fairchild v. Lockhart, 675 F. Supp. 469 (1987). The Supreme Court held (1) Petitioner's reliance on Fairchild was unavailing, and even if Petitioner's arrest was illegal, it does not follow that his charges should be dismissed; and (2) Petitioner failed to establish any basis for the Supreme Court to recall its mandate. View "Logan v. State" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's petition seeking an extraordinary writ pursuant to the "all writ act" section 1651, holding that the circuit court did not clearly err when it denied Appellant's petition for an extraordinary writ.In his petition, Appellant, an inmate, sought to challenge the admissibility of evidence seized in an allegedly illegal search. The circuit court treated the petition as a petition for writ of habeas corpus and denied it. The Supreme Court affirmed, holding that, to the extent that Appellant sought a writ of habeas corpus, he did not state a cognizable claim. View "Douthitt v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of audita querela and for relief pursuant to Ark. R. Civ. P. 26(k), holding that the circuit court properly considered Appellant's petition as a coram nobis petition and that Appellant did not state a ground for a writ of error coram nobis.Appellant, an inmate, alleged in his petition for writ of audita querela that he was entitled to resentencing and that the judgment in his criminal case was invalid. The circuit court treated the petition as a petition for writ of error coram nobis and dismissed the petition. The Supreme Court affirmed, holding (1) it was not error for the circuit court to consider Appellant's petition as a coram nobis petition; and (2) the allegations that Appellant raised did not fit within the categories for claims that warrant issuance of a writ of error coram nobis. View "Jefferson v. State" on Justia Law

The Supreme Court dismissed this appeal from the circuit court's denial of Appellant's pro se petition for writ of habeas corpus, which rendered moot Plaintiff's motion seeking an extension of time to file his brief in chief, holding that Appellant could not prevail on appeal.In denying the petition, the Pulaski County Circuit Court found that Appellant failed to show that his conviction was invalid on its face or that the trial court lacked jurisdiction. The Supreme Court dismissed Appellant's appeal, holding that although Appellant was incarcerated in Pulaski County when he filed the habeas petition, a writ of habeas corpus issued by the Pulaski County Circuit Court could not be returned there because Appellant was no longer within its jurisdiction. View "Ramirez v. Kelley" on Justia Law

The Supreme Court affirmed the order of the trial court dismissing an in forma pauperis petition to proceed with a pro se petition for a writ of error coram nobis and a motion for appointment of counsel on the basis that Appellant failed to state a colorable cause of action, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to grant the relief sought.Appellant pleaded guilty to raping his daughter on several occasions. Appellant later filed three pleadings relating to his request for a writ of error coram nobis. The trial court dismissed the pleadings for failure to state a colorable claim for the issuance of a writ of error coram nobis. The Supreme Court affirmed, holding that the trial court did not abuse its discretion when it concluded that Appellant failed to state a basis for coram nobis relief. View "French v. State" on Justia Law

The Supreme Court reversed the circuit court's order to expunge Appellant's felony conviction under Act 531 of 1993, holding that the circuit court did not have the authority to expunge Appellant's conviction as a matter of law.Appellant pleaded guilty to Class C felony theft of property. Appellant was sentenced to three years of probation, and the conditions of probation referenced Act 531, known as the Community Punishment Act. In 2011, Appellant pleaded guilty to failing to comply with the conditions of probation. The court resentenced Defendant to four years of probation, but the new order omitted any reference to the Act. Appellant later petitioned to expunge her conviction under Act 531. The circuit court granted the petition. The Supreme Court reversed, holding that Appellant failed successfully to complete probation under Act 531 and was thus ineligible for expungement under the Act's provisions. View "State v. Brown" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's request seeking postconviction DNA testing of twenty-six pieces of evidence under Act 1780, holding that the circuit court properly found that Defendant failed to meet the predicate requirements for testing.Defendant was twice convicted and sentenced to death for the murder of Carol Heath. All of Defendant's challenges to his conviction were unsuccessful. Here, Defendant sought postconviction DNA testing claiming that the proposed testing could undermine the prosecution's case or exonerate him. The circuit court found that Defendant had not satisfied the requirements for testing under Act 1780. The Supreme Court affirmed, holding that none of the evidence that might result from the proposed testing could advance Defendant's claim of actual innocence or raise a reasonable probability that he did not murder Carol Heath. View "Johnson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, holding that the circuit court did not err when it denied Defendant's directed verdict motion because there was sufficient evidence to support the conviction.Specifically, Defendant argued that there was insufficient evidence that he was guilty of either capital or first-degree murder as felony murder during a rape or an attempted rape or intentional murder. The Supreme Court affirmed, holding that the evidence was sufficient to uphold the jury's capital murder conviction and that, after examining the record in compliance with Ark. Sup. Ct. R. 4-3(i), no adverse ruling involved prejudicial error. View "Chumley v. State" on Justia Law