Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the circuit court's order denying Appellant's petition to proceed in the circuit court as a pauper with a petition for writ of habeas corpus, holding that none of Appellant's arguments on appeal demonstrated reversible error.In his habeas petition, Appellant challenged his convictions for four counts of computer exploitation of a child in the first degree and twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The circuit court found that Appellant presented sufficient evidence that he was indigent but that the allegations in the petition did not present a colorable cause of action. The Supreme Court affirmed, holding that Appellant's arguments made in the habeas petition were insufficient to present a colorable cause of action for habeas relief. View "Rea v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's motion for a new trial or other relief in which he sought a new sentencing hearing on his aggravated robbery conviction, holding that the circuit court did not err by denying the motion for new trial or other relief.On appeal, Appellant argued that his thirty-five-year sentence for aggravated robbery violated the protection afforded him by the federal Constitution because the jury was improperly instructed that it could consider and impose and sentence of life imprisonment, contrary to the holding in Graham v. Florida, 560 U.S. 48 (2010). The Supreme Court affirmed, holding that the circuit court was without jurisdiction to entertain Appellant's argument and thus did not err in denying Appellant's motion for new trial or other relief. View "Whiteside v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court remanded this matter to the circuit court to settle the record, holding that this Court was unable to reach the merits of this appeal from the judgment of the circuit court finding Defendant guilty of first-degree murder, aggravated robbery, and theft of property.On appeal, Defendant argued that substantial evidence did not support his convictions, the circuit court abused its discretion on a juror misconduct allegation, and the record was inadequate on jury questions during deliberations. The Supreme Court remanded the case to the circuit court to settle the record, holding that the record was insufficient. View "Terry v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the writ.Appellant pleaded guilty to aggravated robbery and was sentenced to a term of imprisonment. In his petition for a writ of error coram nobis Appellant alleged that his counsel did not fully explain his parole eligibility or the effect of his prior convictions, and therefore, he was coerced into pleading guilty. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant's allegations did not rise to the level of coercion sufficient to meet his burden of establishing grounds for the writ. View "Brown v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a ground on which the writ could issue under Arkansas law.Appellant pleaded guilty to first-degree murder and was sentenced as a habitual offender to 600 months' imprisonment. In his habeas corpus petition, Appellant asserted several grounds for the writ. The circuit court concluded that the habeas petition was meritless. The Supreme Court affirmed, holding that where Appellant's petition consisted of blanket assertions that failed to show that there was a ground for the writ, the circuit court did not err in denying the petition. View "Loving v. Straughn" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner did not provide a meritorious basis for issuance of the writ.Petitioner was convicted of four counts of rape. In his coram nobis petition, Petitioner alleged that there was exculpatory information that was unknown and not addressed at trial. Petitioner then filed a motion "to show cause for coram nobis" asserting additional bases for the writ. The Supreme Court treated the motion to show cause as a motion to supplement the petition to reinvest jurisdiction and denied it as well as the coram nobis petition, holding that Petitioner's proposed attack on the judgment was not meritorious. View "Jones v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally.Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law

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The Supreme Court affirmed Appellant's convictions for capital murder and aggravated robbery, holding that none of Appellant's allegations of error warranted reversal.Specifically, the Court held (1) the State presented sufficient circumstantial evidence to support the convictions, and therefore, the circuit court did not err in denying Appellant's motion for directed verdict; (2) the circuit court did not abuse its discretion by denying Appellant's motion to exclude as hearsay testimony about the businesses Appellant called after the shooting; and (3) the circuit court did not err in denying Appellant's posttrial motion for mistrial because the jury's verdicts were consistent. View "Finley v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the circuit court dismissing for lack of jurisdiction Appellant's appeal from a district court judgment convicting him of driving while intoxicated and a speeding violation, holding that the circuit court erred in granting the State's motion to dismiss based not he circuit court's lack of jurisdiction.The circuit court dismissed Appellant's appeal of his conviction in district court as untimely pursuant to Ark. R. Crim. P. 36(c). On appeal, Appellant argued that the circuit court erred because the appeal was timely filed pursuant to Rule 36(d). The Supreme Court reversed, holding that the filing of Appellant's affidavit triggered jurisdiction of his appeal and strictly complied with Rule 36(d) to commence an appeal from the district court to the circuit court. View "Treat v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's convictions of rape and second-degree sexual assault, holding that the circuit court did not commit prejudicial error in allowing testimony from Defendant's daughter under the pedophile exception and allowing the State to inquire on cross-examination about a disputed police report.Specifically, the Court held (1) the circuit court did not abuse its discretion when it admitted the testimony of Defendant's daughter that Defendant sexually abused her when she was five or six years old; and (2) the circuit court erred by allowing the State to inquire on cross-examination about a disputed police report, but the error was harmless. View "Lowery v. State" on Justia Law

Posted in: Criminal Law