Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court convicting Appellant of two counts of first-degree murder, one count of attempted first-degree murder, and other crimes and sentencing him to three counts of life imprisonment and one term of fifty years to run consecutively, holding that the circuit court did not err in denying Appellant's motion for mistrial.On appeal, Appellant argued that the circuit court erred in denying his motion for mistrial because certain testimony was so prejudicial that no admonition to the jury could have cured it. The Supreme Court affirmed, holding that the testimony did not warrant a mistrial. View "Thompson v. State" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of mandamus asking the circuit court to compel the Arkansas Board of Parole to set aside the revocation of his parole, holding that the circuit court correctly denied the petition for writ of mandamus.The circuit court denied the petition on the basis that mandamus does not lie to correct matters that are discretionary. Appellant appealed and also filed a motion to supplement his brief. The Supreme Court denied Appellant's motion to supplement his brief and affirmed the circuit court's denial of his mandamus petition, holding that the circuit court correctly denied the petition because mandamus does not lie to control a public official's discretionary act. View "Martz v. Felts" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for a writ of error coram nobis and audita querela, holding that Appellant failed to establish grounds for issuance of the writ.Appellant pleaded guilty to three counts of capital murder. In the instant action Appellant asserted multiple claims for coram nobis relief. Specifically, Appellant alleged that the circuit court was biased, that the State committed a Brady violation, and that he was suffering from a mental defect when he pled guilty. The circuit court denied the claims. The Supreme Court affirmed, holding that the petition for coram nobis relief clearly had no merit. View "Stocks v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's claims for postconviction relief that were raised pursuant to Ark. R. Crim. P. 37.1, holding that Appellant raised claims that were not cognizable in Rule 37.1 proceedings and failed to establish prejudice as a basis to support his ineffective assistance of counsel claims.Appellant was convicted of murder in the first degree and abuse of a corpse and sentenced as a habitual offender. Appellant filed a timely petition for Rule 37.1 relief, arguing that juror misconduct, prosecutorial misconduct, and an illegal search violated his right to due process and that he received ineffective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding (1) the only cognizable claims were the ineffective assistance of counsel claims that Appellant raised below and reasserted on appeal; and (2) the trial court did not clearly err when it found that Appellant had failed to demonstrate that he suffered prejudice as a result of his counsel's alleged errors. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis filed by Petitioner, holding that Petitioner failed to state sufficient facts to establish a violation of Brady v. Maryland, 373 U.S. 83 (1963).Petitioner was convicted of robbery, theft of property, and employment of a firearm to commit aggravated robbery. In his coram nobis petition, Petitioner alleged that exculpatory testimony of two witnesses was suppressed in violation of Brady. The Supreme Court denied the petition, holding that Petitioner did not state facts that established a Brady violation but, instead, alleged ineffective assistance of counsel claims, which are not cognizable in coram nobis proceedings. View "Talley v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court so that she may file a petition for writ of error coram nobis in her criminal case, holding that Petitioner's claims did not establish a ground for the writ.Petitioner was convicted of aggravated robbery and theft of property and sentenced to an aggregate term of 480 months' imprisonment. The court of appeals affirmed. In her coram nobis petition Petitioner claimed that there was a conflict of interest in her representation, a Brady violation, and misconduct on the part of the prosecutor. The Supreme Court denied the petition, holding that Petitioner failed to state sufficient allegations to satisfy issuance of the writ. View "Joiner v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition to proceed in forma pauperis in a habeas proceeding, which rendered moot Appellant's motion to supplement the record, holding that the circuit court did not abuse its discretion in denying Appellant's petition.In denying the petition, the circuit court found that the petition for writ of habeas corpus raised a jurisdictional issue that had already been decided. The Supreme Court affirmed, holding that the circuit court properly denied the petition and that this Court already addressed the issue raised by Appellant in a prior appeal. View "Russell v. Kelley" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant did not state a ground for the writ.Appellant, who was convicted of residential burglary and rape, filed his habeas petition in the county where he was currently incarcerated, alleging that he had been denied a speedy trial. The circuit court dismissed the habeas petition on the merits, holding that Appellant had not been denied a speedy trial. The Supreme Court affirmed, holding that the circuit court properly dismissed the petition and did not err in not holding a hearing on the petition. View "Noble v. State" on Justia Law

The Supreme Court treated the three pro se motions filed by Petitioner seeking leave to proceed with an appeal of an order that denied his motion for writ of habeas corpus as motions for belated appeal and denied the motions, holding that Petitioner did not meet his burden of establishing good cause for not abiding by the rules that govern the orderly administration of justice.Petitioner filed to file a timely notice of appeal from the order from which he sought to appeal. Petitioner also filed a motion to correct the circuit court's order and other motions. The Supreme Court denied Petitioner's request to proceed with a belated appeal and declared moot the remaining motions, holding that Petitioner failed to show good cause for his failure to file a timely notice of appeal. View "D'Angelo v. State" on Justia Law

The Supreme Court reversed the firearm enhancements applied to Defendant's sentence and affirmed Appellant's convictions and sentences in all other respects, holding that because the jury did not find beyond a reasonable doubt that Appellant used a firearm as a means of committing terroristic acts, his twenty-nine one-year sentences imposed as firearm enhancements must be reversed.Defendant was convicted of first-degree murder, a terroristic act causing death, and twenty-eight counts of terroristic acts. Further, Defendant was subject to enhanced penalties pursuant to Ark. Code Ann. 16-90-120, the firearm-enhancement statute. The Supreme Court struck the firearm enhancements but otherwise affirmed, holding that the jury did not clearly find that Defendant employed a firearm as a means of committing the twenty-nine terroristic acts, and therefore, the twenty-nine firearm enhancements imposed by the jury must be reversed. View "Ellis v. State" on Justia Law