Justia Arkansas Supreme Court Opinion Summaries

In this case, the appellant, William Nelson, appealed his conviction of first-degree domestic battery by a Lonoke County jury in the Supreme Court of Arkansas. He raised seven points on appeal: (1) substantial evidence did not support his conviction; (2) the circuit court’s refusal to recuse was an abuse of discretion; (3) the circuit court improperly denied his Batson objection; (4) the circuit court abused its discretion by limiting questions regarding sentencing during voir dire; (5) the circuit court allowed inadmissible prior-bad-acts evidence to be introduced; (6) refusal to dismiss a juror for-cause during trial was an abuse of discretion; and (7) the circuit court improperly restricted expert witness testimony or, alternatively, erred by denying a motion for a continuance to obtain a new expert. The State cross-appealed, arguing that the circuit court misinterpreted the statutory requirement to support a sentencing enhancement and improperly granted Nelson’s directed-verdict motion on the issue.The court affirmed Nelson's conviction on all points. It found that substantial evidence supported the conviction and the circuit court did not abuse its discretion in any of the contested decisions. In the cross-appeal, the court dismissed the State's appeal, ruling that it did not present an issue of interpretation of the criminal rules with widespread ramifications and the resolution of the issue turned on the facts unique to the case. View "NELSON v. STATE OF ARKANSAS" on Justia Law

In the case, Royce Calkins appealed a Stone County Circuit Court order that convicted him of two counts of first-degree murder and sentenced him to two consecutive terms of life imprisonment, plus a fifteen-year sentencing enhancement to each term for using a firearm. Calkins had shot and killed his girlfriend and father in a shared home. The Supreme Court of Arkansas confirmed the conviction and sentence on appeal.Calkins argued two points on appeal. First, he challenged the sufficiency of the evidence supporting his first-degree-murder convictions, and second, he argued that the circuit court abused its discretion by denying his proffered jury instructions on justification and kidnapping.Regarding the first point, Calkins argued that there was no proof that he intended to kill anyone. The court, however, found substantial evidence supporting both counts of first-degree murder. The court considered the fact that Calkins shot each victim multiple times, attempted to stage the scene to make it look like a murder-suicide, and fled the scene as evidence supporting his purposeful intent.Regarding the second point, Calkins argued that the circuit court erred in refusing to provide jury instructions on justification and kidnapping. The court found no abuse of discretion in the circuit court's refusal to instruct the jury on these issues, as there was no rational basis in the evidence for such instructions. The court noted that Calkins's statements to a physician about his fear of being hurt by the victims did not constitute evidence of a reasonable belief that he was in imminent danger, nor was there evidence to support the claim of kidnapping. Therefore, the Supreme Court of Arkansas affirmed the circuit court's decision. View "ROYCE CALKINS v. STATE OF ARKANSAS" on Justia Law

The Supreme Court of Arkansas upheld the first-degree murder conviction of Ricky Lewis Neal, a blind man who was sentenced as a violent-felony habitual offender to life imprisonment. The case arose from the death of Neal’s fiancée, Alice Cawley. Neal had expressed dissatisfaction with his appointed counsel multiple times and sought to represent himself before trial. He also objected to the admission of hearsay evidence in the form of a lost voicemail from the victim saying that Neal was trying to kill her. The court ruled that Neal did not unequivocally invoke his right to self-representation, as his statements indicated that he was simply dissatisfied with his counsel and wanted new counsel, rather than wanting to waive his right to counsel. Regarding the hearsay evidence, the court found that the victim’s statement expressing fear of Neal fell within the hearsay exception for a declarant's then-existing state of mind, emotion, or sensation in Rule 803(3) of the Arkansas Rules of Evidence. Therefore, the court affirmed the conviction and sentence. View "Neal v. State" on Justia Law

In 1980, Thernell Hundley was convicted of capital murder and rape, and received a life sentence without parole. In 2012, the Supreme Court ruled that life sentences without parole for juvenile offenders were unconstitutional, and Hundley's life sentence for capital murder was vacated. However, during his incarceration, Hundley had committed four additional felonies. As a result, the Jefferson County Circuit Court in Arkansas ruled that Hundley was ineligible for parole based on Arkansas Code Annotated section 16-93-607(c)(5), which states that inmates classified as fourth offenders are not eligible for parole.Hundley appealed this decision, arguing that his rape conviction should be vacated as it was merged with the capital murder charge, that he should be eligible for parole under the Fair Sentencing of Minors Act, and that his parole eligibility should be determined by the law in effect when he committed his first crimes in 1979. He also challenged the inclusion of his two Class D felony convictions in determining his parole eligibility.The Supreme Court of Arkansas upheld the circuit court's decision. The court ruled that Hundley's separate conviction for rape was not illegal and could not be vacated. The court further held that Hundley's parole eligibility was correctly determined based on the law in effect at the time he committed his last two felonies in 1988 and 1989, not the law at the time of his original crimes. The court also clarified that Hundley's parole ineligibility was based on his convictions for capital murder, rape, attempted first-degree murder and first-degree battery, not his two Class D felonies. View "Hundley v. Payne" on Justia Law

In the Supreme Court of Arkansas, the defendant, Kevonce Ephriam, was appealing his conviction for capital murder. Ephriam was convicted for the death of his three-month-old son, whom he had custody of at the time of the incident. The child sustained numerous injuries, including bruises to his head, forehead, face, neck, and tongue; abrasions to his nose and neck; a torn frenulum; fractured ribs and vertebrae; and hemorrhaging in the soft tissue along his spinal column and on his neck, abdomen, and chest. Ephriam attempted to explain some of the injuries as accidents or results of his attempts to perform CPR, but his explanations were refuted by medical experts.Ephriam argued that the State did not present sufficient evidence for capital murder and that his son's death could have been accidental. He also argued that the jury had to resort to speculation and conjecture to determine that he knowingly caused his son’s death under circumstances manifesting extreme indifference to the value of human life.The court affirmed the conviction, finding that substantial evidence supported the capital-murder conviction. The court reasoned that the defendant admitted to threatening to harm the child and the mother, and his explanations for the child's injuries were refuted by medical experts, which led the jury to reasonably conclude that the injuries were not accidental but were inflicted by the defendant. The court also stated that there was no dispute that the child was under fourteen and that Ephriam was over eighteen at the time of the murder, fulfilling the age criteria for capital murder under Arkansas law. View "Ephriam v. State" on Justia Law

In this case from the Supreme Court of Arkansas, defendant Robert J. Williams, Jr. appealed his conviction for capital murder and aggravated assault. Williams argued that the trial court erred in granting the State's motion for continuance, violated his rights to a speedy trial, and improperly denied his Batson challenge during jury selection. The Supreme Court of Arkansas disagreed and affirmed the lower court's decision.On the issue of the continuance, the court held that the trial court did not abuse its discretion in granting the State's motion for continuance. The court found that the State acted with due diligence and the affidavit submitted by the State substantially complied with the requirements set forth by law.On the issue of speedy trial, the court conducted a de novo review to determine whether specific periods of time were excludable under the speedy-trial rules. The court found that Williams was brought to trial within the twelve-month period required by the rules. Therefore, the court held that Williams's right to a speedy trial was not violated.Finally, on the issue of the Batson challenge, the court held that the trial court properly allowed the State to strike a juror based on a race-neutral reason, that is, the juror's lack of involvement in the judicial process. The court deferred to the trial court's ability to gauge the State's demeanor and credibility, finding no error in the denial of the Batson challenge.Therefore, the court affirmed the decisions of the lower court, finding no prejudicial error. View "Williams v. State" on Justia Law

In 1992, Darren Woodruff, the appellant, was convicted of capital murder and sentenced to life imprisonment without parole in Arkansas. In 2023, he appealed pro se, claiming that his sentence was illegal because he was not convicted of an underlying felony and the sentencing order lacked the subsection of capital murder of which he was convicted. The circuit court denied his petition, stating that the sentence was not illegal on its face and that the punishment for capital murder had not been exceeded.The Supreme Court of Arkansas affirmed the circuit court's decision. Firstly, the court noted that the statute in effect when Woodruff committed the offense in June 1991 did not require an underlying felony. Therefore, his claim that his sentence was illegal because he was not convicted of an underlying felony was not valid. Secondly, the court held that Woodruff's claim that the sentencing order lacked the subsection of capital murder was not a matter that implicated the facial validity of the judgment and was therefore subject to the time limitations set out in Arkansas Rule of Criminal Procedure 37.2(c). Since Woodruff filed his petition approximately thirty years after the judgment in his case was affirmed, his petition was not within the required time limits. Thus, the court concluded that his sentence was not illegal, and his petition was not timely. View "Woodruff v. State" on Justia Law

In the Supreme Court of Arkansas, Jason Farmer, an inmate, appealed the denial of his pro se petition for writ of habeas corpus, which he filed alleging ineffective assistance of his trial and appellate counsel, as well as prosecutorial, juror, and judicial misconduct. Farmer was previously convicted of several crimes and sentenced to a cumulative term of twenty-two years in prison, a conviction and sentence that were affirmed by the Arkansas Court of Appeals. In this appeal, Farmer argued that the circuit court lacked jurisdiction to deny his petition because it failed to first issue an order on his petition to proceed in forma pauperis (as a poor person) in accordance with Rule 72 of the Arkansas Rules of Civil Procedure. He relied on a previous court decision, Ward v. Hutchinson, to support his argument.However, the Supreme Court of Arkansas disagreed with Farmer's interpretation. It clarified that the cited case, Ward v. Hutchinson, pertained to a civil-rights complaint, not a postconviction petition, and in that case, the complaint was not file-marked or entered on the docket, unlike Farmer's petition. The Supreme Court of Arkansas affirmed the circuit court's decision to deny and dismiss Farmer's petition. It held that the circuit court had jurisdiction to determine whether Farmer had stated a colorable cause of action because his petition was properly filed and placed on the docket. The Supreme Court of Arkansas further explained that a writ of habeas corpus is proper when a judgment and commitment order is invalid on its face or when a circuit court lacks jurisdiction over the cause. Farmer's claims, however, went beyond the face of the judgment and were therefore not cognizable in habeas proceedings. View "Farmer v. Payne" on Justia Law

In November 2020, Deputy James Oswald found Rhys Franklin asleep in a parked car on the side of the road. Franklin exhibited signs of intoxication, admitted to drinking, and refused to submit to a field sobriety test. He was arrested on suspicion of driving while intoxicated (DWI) and later refused to submit to any chemical tests at the detention center. At his jury trial, Franklin's defense counsel moved for a mistrial twice, first when Deputy Oswald mentioned a portable breath test (PBT) result in response to the defense's questioning and second when another officer, Omar Gonzales, voluntarily mentioned that a PBT was administered. Both motions were denied by the Scott County Circuit Court. Franklin was convicted of DWI and refusal to submit to a chemical test. The Court of Appeals reversed the convictions, but the Supreme Court of Arkansas granted the State's petition for review.The Supreme Court of Arkansas held that the circuit court did not abuse its discretion in denying the motions for a mistrial. The court found that the defense's questioning invited Deputy Oswald's mention of the PBT result, which made it an invited error that the defense could not complain about. In the case of Gonzales's statement, the court found that it was not a foreseeable response to the prosecution's question and was not deliberately induced by the prosecution. Furthermore, the mention of the PBT without the results was viewed as a harmless error, given the substantial evidence of Franklin's guilt. The court also pointed out that any potential prejudicial effect of the officers' statements could have been mitigated by a curative instruction, which the court offered but the defense declined. The court affirmed the convictions and vacated the opinion of the Court of Appeals. View "FRANKLIN v. STATE" on Justia Law

The Supreme Court of Arkansas affirmed the first-degree murder conviction and life imprisonment sentence of Justin Petty, who appealed on the grounds that the trial court had abused its discretion when it denied his requests for a mistrial. The mistrial requests arose from a witness's unanticipated reference to Petty's prior jail time, which Petty argued violated a pretrial order prohibiting discussion of his prior bad acts. The trial court ruled that the violation was minor since the term "jail," as used in this context, did not indicate a conviction. Furthermore, the trial court had instructed the jury to disregard the statement, and the jury agreed to do so. On appeal, the Supreme Court agreed with the trial court's reasoning, concluding that the mention of "jail" was not significantly prejudicial, and that the prosecutor had not intentionally elicited the prohibited information. The Supreme Court, therefore, affirmed the trial court’s decision, holding that there had been no abuse of discretion in denying Petty's mistrial motions. View "Petty v. State" on Justia Law