Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that the trial court did not abuse its discretion in denying coram nobis relief.Appellant pleaded guilty to one count of rape. In his petition, Appellant alleged that his guilty plea was the result of fraud and coercion because the terms of the plea agreement were changed after he signed it and his trial counsel coerced him into "answering loudly and affirmatively" during the plea hearing. The trial court denied the petition for failing to state a cognizable claim for the issuance of the writ. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying Appellant's petition for a writ of error coram nobis where Appellant was properly informed of the charges to which he was pleading guilty and where Appellant presented no evidence that his guilty plea was coerced. View "Malone v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of error coram nobis or to vacate his conviction, holding that the circuit court did not err in denying the petition.Appellant pleaded nolo contendere to first degree battery and unlawful possession of a firearm. Appellant later filed a pro se petition for writ of error coram nobis or to vacate his conviction, arguing that his plea was coerced because his attorney rendered ineffective assistance of counsel during the plea hearing. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's allegations of ineffective assistance and his conclusory conspiracy accusation did not present a valid claim for coram nobis relief. View "Jones v. State" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant's pro se motion to vacate his amended sentencing order entered under the Fair Sentencing of Minors Act of 2017 (FMSA) and remanded for resentencing in accordance with the decision in Harris v. State, 547 S.W.3d 64 (Ark. 2018), holding that the circuit court lacked the authority to sentence Appellant under the FSMA.Appellant was sixteen years old when he was convicted of capital murder. Following the decision in Miller v. Alabama, 567 U.S. 460 (2012), Appellant petitioned for a writ of habeas corpus. The circuit court issued the writ, vacated Appellant's mandatory sentence of life without parole, and remanded for resentencing. Before Appellant's resentencing hearing, however, the FSMA was passed. The circuit court subsequently sentenced Appellant to life imprisonment with the possibility of parole after thirty years pursuant to the FSMA. Appellant filed a pro se motion to vacate the amended sentencing order. The circuit court concluded that it lacked jurisdiction to rule on Appellant's motion to vacate. The Supreme Court reversed, holding that, pursuant to its decision in Harris, the circuit court erred in applying the FSMA to Appellant's case, and Appellant was entitled to a hearing to present Miller evidence for consideration. View "Scherrer v. State" on Justia Law

The Supreme Court denied Petitioner's seventh pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise claims that were cognizable in coram nobis proceedings.Petitioner was convicted of two counts of rape. In his coram nobis petition at issue in this case Petitioner raised new claims of ineffective assistance of counsel and reasserted a conflict of interest claim, both of which were either raised and rejected or should have been raised in a previous Ark. R. Crim. P. 37.1 proceeding. The Supreme Court denied the petition, which rendered moot Petitioner's motion to rebut the State's response to his petition, holding that, as with his first six petitions, Petitioner asserted claims that were not cognizable in a petition to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court dismissing Appellant's pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that the trial court correctly denied relief where Appellant failed to establish that his sentence was illegal and the petition was untimely filed.Appellant was found guilty in 1993 of aggravated robbery and other offenses. In his petition under section 16-90-111 Appellant alleged that the sentence for aggravated robbery was illegal because it exceeded the "mandatory minimum" sentence permitted under the sentencing statutes in effect when he committed the offenses and that his convictions violated the Double Jeopardy Clause. The Supreme Court affirmed the trial court's denial of the petition, holding that Appellant was not entitled to relief because, pursuant to either section 16-90-111 or Ark. R. Crim. P. 37.1, Appellant's petition was not timely filed. View "Wesley v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for coram nobis relief, holding that Petitioner failed to establish that the trial court abused its discretion and that the writ should have issued.Appellant pleaded guilty to first-degree battery and other offenses. Ten years later, Appellant filed a second pro se petition for writ of error coram nobis challenging the judgment. The trial court denied relief. The Supreme Court reversed and remanded, concluding that Appellant's Brady claim may have merit and that the trial court should hold an evidentiary hearing to consider the merits of the petition. On remand, after an evidentiary hearing, the trial court again denied relief. Appellant appealed, raising six claims of error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying the writ for coram nobis relief. View "Scott v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, aggravated robbery, and a firearm enhancement, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the circuit court erred in denying his motion to suppress his statements to police recorded in a police interrogation room and an alleged nonrecorded custodial statement made while police escorted him to a police car. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in rejecting Defendant's argument that the issuance of Miranda warnings was rendered ineffective; and (2) Defendant's remaining allegations of error were without merit. View "Pree v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of rape of a minor and sentence of life imprisonment without parole, holding that the circuit court did not err in denying Defendant's motions to dismiss and did not abuse its discretion in admitting certain evidence.Specifically, the Court held that the circuit court (1) did not err in denying Defendant's motion to dismiss for violating Defendant's right to a speedy trial because Defendant's speedy trial rights were not violated; (2) did not err in denying Defendant's motion to dismiss for prosecutorial delay because Defendant was not prejudiced by the delay of filing the charges; and (3) did not abuse its discretion in admitting an Arkansas Department of Correction "pen pack" and an Arkansas Court of Appeals opinion as evidence of prior convictions. View "Rayburn v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held that the trial court (1) did not err by denying Defendant's motion for directed verdict because there was sufficient evidence that Defendant acted with the purpose of causing the death of the victim; (2) did not abuse its discretion in allowing testimony over Defendant's objection involving prior incidents unrelated to the night of the charged murder; and (3) did not err in refusing Defendant's motion for a jury instruction on justification for manslaughter because the jury never considered manslaughter. View "Coakley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of capital murder and first-degree battery, holding that the circuit court did not abuse its discretion in denying Defendant's motion for mistrial.On appeal, Defendant argued that a mistrial was warranted on the basis of a witness's statements during cross-examination. During trial, the witness accused defense counsel of threatening him and making other statements suggesting that defense counsel was trying to conceal evidence of Defendant's guilt. The Supreme Court affirmed, holding that the statement was not of such magnitude that it was an abuse of discretion for the circuit court to deny the motion for a mistrial, and the circuit court's admonition to the jury was sufficient to cure any possible prejudice stemming from the witness's remarks. View "Braud v. State" on Justia Law