Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's pro se petition seeking to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claims did not establish a ground for the writ.Petitioner was convicted of possession of a controlled substance and other offenses and sentenced as a habitual offender to an aggregate term of 504 months' imprisonment. In his petition, Petitioner asserted that Brady v. Maryland, 373 U.S. 83 (1963), violations occurred based on prosecutorial misconduct. The Supreme Court denied the petition, which rendered moot the motions Petitioner filed in connection with the petition, holding that Petitioner failed to demonstrate that the State withheld any evidence or otherwise violated Brady. View "Ivory v. State" on Justia Law

The Supreme Court denied Petitioner's amended motion for belated appeal of a judgment reflecting his conviction on charges of fleeing and endangering the welfare of a minor, holding that the trial court's conclusions regarding whether Petitioner was advised of his right to appeal or whether he notified his attorney of his desire to appeal were supported by the transcript.Because Petitioner made representations that conflicted with those made by his attorney, the Supreme Court remanded the matter to the trial court for additional findings of fact. The trial court found that Petitioner was advised about his right to appeal and did not timely articulate a desire to appeal. The Supreme Court denied Petitioner's motions for belated appeal, holding that Petitioner's attorney acted in a professionally reasonable manner by not filing a notice of appeal, and therefore, Petitioner was not entitled to a belated appeal. View "Simpson v. State" on Justia Law

The Supreme Court dismissed this appeal from an order of the circuit court granting Appellees' motion to dismiss Appellants' complaint for lack of standing and for failure to state a cause of action, holding that the circuit court properly ruled that Appellant First Arkansas Bail Bonds, Inc. did not have standing and that the declaratory judgment claim was moot.Appellants sought a declaratory judgment finding that Appellees, the district judge of Saline County, Benton and the district judge of Saline County, Bryant, had violated Ark. Const. art. II, 8 by failing to allow defendants to use a licensed bail-bond company. The circuit court found (1) the declaratory judgment claim was moot because Appellant James Toland had paid his sheriff's bond, most of that payment was refunded, and Toland had pleaded guilty and remained in the custody of the Arkansas Department of Correction; and (2) First Arkansas lacked standing because it had not been denied the opportunity to pay Toland's bond. The Supreme Court dismissed the appeal from the circuit court's order, holding (1) First Arkansas did not sustain an actual injury, and therefore, it lacked standing; and (2) the declaratory judgment claim was moot, and no exceptions to the mootness doctrine applied. View "Toland v. Robinson" on Justia Law

The Supreme Court granted Petitioner's pro se motion for belated appeal of 2018 judgments and granted Petitioner in forma pauperis status, holding that where counsel was aware that Petitioner wished to appeal, Petitioner was entitled to a direct appeal as a matter of right.At separate trials, Petitioner was convicted of several drug charges and fleeing. In this motion, Petitioner argued that his retained trial counsel failed to pursue an appeal on his behalf. The Supreme Court granted relief, holding that where counsel admittedly was aware that Petitioner wished to appeal and where counsel did not receive direction from Petitioner not to appeal counsel did not comply with Ark. R. Crim. P. 16. The Court also granted Petitioner in forma pauperis status for the purpose of having the transcript prepared for the appeal. View "Cribbs v. State" on Justia Law

The Supreme Court denied Petitioner's pro se motion requesting copies of his case file pursuant to Ark. R. App. P.-Crim. 19(b), holding that Petitioner did not demonstrate a compelling need for paper copies.At issue was Petitioner's request that the Supreme Court order Gregg Parrish, executive director of the Arkansas Public Defender Commission, to provide paper copies of the material contained on an electronic disk provided to Parrish by the circuit court. Parrish responded that he did not possess paper copies of a client file and was not obligated to convert the electronically stored material to paper. The Supreme Court denied the motion, holding that Petitioner made no showing of a compelling need for paper copies of the electronically stored material. View "Epps 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, holding that Appellant's habeas petition was clearly without merit.Appellant filed a pro se petition for writ of habeas corpus in the circuit court, arguing, inter alia, that the trial court lacked jurisdiction to enter a judgment reflecting Appellant's conviction on a charge of second-degree murder as a habitual offender. The circuit court denied the dismissed the petition. Appellant appealed and filed pro se motions in which he sought a copy of documents from the record on appeal in order to prepare his brief and some accommodation for the delay in filing his brief. The Supreme Court dismissed the appeal, which rendered the motions moot, holding that Appellant's habeas petition was clearly without merit. View "Rainer v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for post conviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court correctly denied Appellant's Rule 37.1 petition.Specifically, the Court held that the circuit court (1) did not clearly err by finding that trial counsel's failure to obtain a forensic evaluation prior to Appellant's pleading guilty was not ineffective assistance; (2) did not err in finding that trial counsel was not ineffective by failing to file any pretrial motions to suppress or motions in limine before permitting Appellant to enter his plea; and (3) did not apply the wrong legal standard in ruling on Appellant's petition. View "Roos v. State" on Justia Law

The Supreme Court affirmed Appellant's two capital murder convictions, a firearm enhancement, and Appellant's sentence of death, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Court held that the circuit court (1) did not abuse its discretion in limiting Appellant's use of hypotheticals during voir dire; (2) did not abuse its discretion in concluding that a juror that Appellant argued should have been struck for cause could perform the duties of a juror; (3) did not abuse its discretion in denying Appellant's mistrial motion; (4) did not err in denying Appellant's request for an admonition; (5) did not abuse its discretion in allowing the State to play a tape recording of a 911 call; (5) did not err in admitting an aggravating circumstance to the jury; and (6) did not abuse its discretion in allowing the State's argument, during closing, that the jury should consider the victim-impact testimony as an aggravator. View "Reid v. State" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's motion for continuance to obtain an independent mental evaluation before convicting him of attempted capital murder, kidnapping, and theft of property, holding that Appellant failed to demonstrate any prejudicial from the denial of the continuance.Appellant sought a continuance to obtain an independent examination to support an affirmative defense of lack of criminal responsibility. The circuit court continued trial to accommodate the examination. After the examination returned unfavorable results, Appellant sought a continuance to obtain an independent evaluation. The circuit court denied the continuance. The Supreme Court affirmed, holding (1) the circuit court properly denied the request on the grounds that Appellant had not acted diligently; and (2) Appellant failed to demonstrate any resulting prejudice amounting to a denial of justice. View "Hendrix v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for writ of error coram nobis, rendering moot Appellant's request to file a belated reply brief, holding that Appellant did not demonstrate that the trial court abused its discretion in declining to issue the writ.In addition to his coram nobis petition Appellant filed a motion in which he sought to modify the record by removing portions that he alleged the trial court incorrectly considered and to seal the record. The Supreme Court denied Appellant's motion to modify and seal the record and denied Appellant's coram nobis petition, holding that Appellant's petition was clearly without merit. View "Gordon v. State" on Justia Law