Justia Arkansas Supreme Court Opinion Summaries

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

John Faulkner was convicted of rape, introduction of a controlled substance into the body of another, and tampering. After injecting the victim with ketamine, Faulkner had non-consensual sex with her and later tried to persuade her to recant her police statement. Faulkner appealed the convictions, arguing that the evidence was insufficient for the tampering conviction, and challenging two evidentiary rulings. The Supreme Court of Arkansas affirmed the lower court's decision.The court found that there was substantial evidence to support the tampering conviction. It held that Faulkner's attempts to have the victim recant her statement to the police were inducements to lie.The court also affirmed the rulings on the evidentiary issues. Faulkner had wanted to introduce evidence of prior sexual relations with the victim to argue that their relationship was consensual. The court held that this evidence was irrelevant because the charge was rape of a physically helpless victim.Furthermore, Faulkner wanted to introduce evidence that he and the victim obtained a marriage license. The court found that this evidence would confuse the jury and was irrelevant, given that the victim's consent was not at issue.The court rejected Faulkner's additional arguments not ruled on below, holding that they had been waived as they were not raised or ruled on in the lower court. View "Faulkner v. State" on Justia Law

In the case before the Supreme Court of Arkansas, the appellant, Marlon Smith, was appealing his conviction and life sentence for first-degree murder. His appeal centered around two main arguments. Firstly, he contended that the lower court erred by not granting his motion for mistrial after a witness testified that he had previously been in prison. Secondly, he argued that the court erred by not granting his motion for a directed verdict, asserting that the evidence presented was insufficient to establish his intent to commit the murder.The court affirmed the conviction and life sentence. With regards to the first argument, the court held that a mistrial was not warranted as a curative instruction to the jury could have resolved the issue. The court also noted that the appellant failed to ensure that such an instruction was given. Regarding the second argument, the court held that there was substantial evidence, including eyewitness testimony and forensic evidence, to support the jury's conclusion that the appellant intended to commit the murder. The court held that the appellant's post-event actions, including his flight from the scene and subsequent lies to the police, were also evidence of his intentional act. Therefore, the court found no error in the lower court's denial of the appellant's motion for a directed verdict. View "Smith v. State" on Justia Law

In this appeal from the Supreme Court of Arkansas, appellant Fred Kimball Sr. was convicted by a Benton County jury on two counts of rape, for which he received two concurrent life sentences. Kimball appealed on the grounds that the statute of limitations barred the prosecution of the charges against him. The statute of limitations in effect when Kimball committed his crimes allowed for prosecution up to the victim’s twenty-fourth birthday, if the offense was not reported to the police or a prosecutor. This period was extended in 2011 and again in 2013 when the statute was amended to allow the prosecution for rape committed against a minor victim to be commenced at any time.Kimball was charged with the rape of three girls, all his granddaughters, prior to 2010. The issue of whether Kimball’s crimes were time-barred was tried by the court prior to his jury trial. Kimball argued that the case involving all three victims should be dismissed because the statute of limitations had run. He asserted that the crimes he was charged with took place no later than 2003, and the statute of limitations in effect lapsed six years later because the State failed to prove beyond a reasonable doubt that a report had not been made.The Supreme Court of Arkansas affirmed the lower court’s decision, holding that the circuit court did not abuse its discretion in refusing to dismiss the charges involving Kimball’s rape of two of the victims. The court reasoned that all three victims testified they did not speak to law enforcement prior to the 2020 investigation. While there was evidence of an investigation into Kimball’s sexual assault of one of the victims, neither of the officers involved in the case recalled that the investigation ever extended to the other victims. The court also rejected Kimball's arguments that certain statements made by family members constituted a report to law enforcement. The court concluded that the statements lacked definitive knowledge of a specific crime or a specific victim. View "Kimball v. State" on Justia Law

In this criminal case before the Supreme Court of Arkansas, the appellant, Fredrick Jones, was convicted by the Pulaski County Circuit Court of first-degree murder, first-degree battery, simultaneous possession of drugs and firearms, possession of cocaine with the purpose to deliver, possession of drug paraphernalia, fleeing, and being a felon in possession of a firearm. Jones was sentenced as a habitual offender to life in prison for the first-degree murder, sixty years in prison for first-degree battery, and an aggregate term of forty years on the remaining convictions, all to be served concurrently.The case resulted from an incident on April 25, 2020, where Jones shot a man and subsequently fled from the police the next day when the victim's daughter identified him. During the high-speed chase, Jones ran a red light, striking a van occupied by Jose and Virginia Hernandez. Jose Hernandez died from his injuries and Virginia Hernandez suffered serious physical injuries. The police discovered firearms and cocaine in Jones's vehicle after the crash.Jones appealed his convictions for first-degree murder and first-degree battery, arguing that the state had failed to prove that these crimes were committed "in furtherance of" his fleeing from police. He contended that while he drove his vehicle at a high speed and ran a red light to evade the police, the collision with the victims' vehicle and the resulting injuries did not promote his flight.The Supreme Court of Arkansas affirmed the lower court's convictions. The court held that there was substantial evidence proving that Jones, with the intent to evade the police (the underlying felony), caused the death of Jose Hernandez and seriously injured Virginia Hernandez in the process of fleeing. The court explained that for a conviction of felony murder, the defendant's primary goal must be the commission of the underlying felony, not the murder or battery itself. The court found that Jones's primary intent was to flee from the police, and in the course of and in furtherance of that flight, he caused the death and serious physical injuries. Therefore, the court ruled that the circuit court properly denied Jones's motions to dismiss. View "JONES v. STATE OF ARKANSAS" on Justia Law

In the case heard before the Supreme Court of Arkansas, the appellant William Tod Rickert was appealing his convictions from the Faulkner County Circuit Court for three counts of rape. Rickert was sentenced as a habitual offender to three life sentences, to be served concurrently. Rickert's main arguments for the appeal were that the circuit court erred by not directing verdicts on each of the three counts of rape; the circuit court abused its discretion in admitting evidence of prior bad acts under the pedophile exception; and the circuit court abused its discretion by admitting the certified copy of his prior Indiana convictions.The Supreme Court affirmed the lower court's decision. The court found that the victim’s uncorroborated testimony describing penetration may constitute substantial evidence to sustain a rape conviction, even when the victim is a child. The court also noted that scientific or medical evidence is not required. The court rejected Rickert's argument that the testimony of prior victims was inadmissible due to their gender difference and the time gap, citing previous cases where such testimonies were upheld. The court also found that the lower court did not err in admitting the certified copy of Rickert's Indiana convictions for the molestation and confinement of a previous victim.Thus, the court affirmed the circuit court's decision and Rickert's convictions. The court also conducted a Rule 4-3(a) review due to the life sentences and found no other prejudicial errors. View "RICKERT v. STATE OF ARKANSAS" on Justia Law

Rodney Dale Harmon was convicted of multiple drug-related felonies and sentenced to forty years in prison. During the execution of a search warrant at Harmon's residence, an HBO documentary film crew was present. The footage of the search, however, could not be obtained. Harmon, in his appeal, claimed that the presence of the film crew violated his Fourth Amendment rights. He filed a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37, which was denied by the circuit court.The Supreme Court of Arkansas affirmed the circuit court’s decision. The court stated that although Harmon argued that the presence of the HBO documentary film crew violated his Fourth Amendment rights, a constitutional violation alone does not trigger the application of Rule 37. The court also stated that issues related to the legality of evidence obtained are not of such a fundamental nature as to void the judgment. The court further noted that Harmon's trial counsel was not ineffective for failing to raise this argument as the remedy for such a violation in the context of a criminal trial is not established law. The court concluded that Harmon's petition conclusively showed that he was entitled to no relief and therefore, the circuit court did not err by dismissing the petition without a hearing. View "HARMON v. STATE OF ARKANSAS" on Justia Law