Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's 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 demonstrate entitlement to error coram nobis relief because he failed to establish an error of fact extrinsic to the record that could not have been raised in the trial court or on direct appeal.Petitioner was convicted of capital murder that was committed in the course of an aggravated robbery. In his coram nobis petition Petitioner raised, among other things, allegations of a prejudicial jury selection process, ineffective assistance of counsel, and an unlawful arrest. Petitioner subsequently filed a motion seeking leave to file a response to the State's response, a motion for file-marked copies at public expense of his petition and other documents, and a motion for appointment of counsel. The Supreme Court denied relief, holding that the proposed claims raised by Petitioner in his petition were based on allegations that were not cognizable in coram nobis proceedings, which rendered moot two of Petitioner's motions. The Court then denied Petitioner's motion for copies at public expense of the documents filed in this pending appeal. View "Martin v. State" on Justia Law

The Supreme Court denied Petitioner's request that the Supreme Court reinvest jurisdiction in the trial court so that it may consider a writ of error coram nobis, holding that Petitioner's petition was without merit.Petitioner was convicted of capital murder. In his coram nobis petition Petitioner primarily disputed the sufficiency of the evidence and also alleged various trial errors and ineffective assistance of counsel. The Supreme Court denied the petition, holding that Petitioner's petition either did not state claims that were cognizable in a coram nobis proceeding or failed to identify any facts to support the basis for the writ that he alleged. View "Johnson v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to reinvest jurisdiction in the trial court so that he may proceed with a petition for writ of error coram nobis in his criminal case, holding that error coram nobis was not available to address Petitioner's claims.In his petition, Petitioner argued that the writ should issue because there were flaws in his trial and in his direct appeal, including trial error, prosecutorial misconduct, due process violations, and ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner did not allege grounds for the writ because none of his claims were based upon information outside of the record or otherwise unknown to Petitioner. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's petition in which he requested that the Supreme Court reinvest jurisdiction in the trial court so that he may file a petition for writ of error coram nobis and audita querela, holding that Petitioner failed to set out a basis in the original petition or in his amended petitions that would support issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to life in prison without possibility of parole. The Supreme Court affirmed. Petitioner then filed the instant petition, alleging, among other things, Brady claims. The Supreme Court denied the petition, holding (1) with the exception of the Brady claims, none of Petitioner's proposed grounds for the writ were cognizable in proceedings for the writ or fell within one of the recognized categories of error to support the writ; and (2) Petitioner's allegations concerning his Brady violation claims were too vague and conclusory and lacked the requisite factual support. View "Alexander v. State" on Justia Law

The Supreme Court dismissed the State's interlocutory appeal from the circuit court's grant of David Reynolds's motion to suppress evidence seized from a search of his cell phone, holding that this was not a proper State appeal.The State appealed under Rule 3 of the Arkansas Rules of Appellate Procedure-Criminal. Noting that an appeal is permitted by Rule 3 when the issue presented is whether the circuit court erred in its interpretation of the law and that the Court does not accept an appeal by the State when the circuit court's decision turns on facts unique to the case or involves a mixed question of law and fact, the Supreme Court dismissed the appeal, holding that the correct and uniform administration of the criminal law was not at issue in this case. View "State v. Reynolds" on Justia Law

The Supreme Court reversed the circuit court's order denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing with Minors Act of 2017 (FSMA), holding that the penalty provisions of the FSMA did not apply to Appellant.In 2000, Appellant pled guilty to capital murder and received a mandatory sentence of life in prison without parole. Appellant was sixteen years old at the time of the murder. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), the circuit court granted habeas relief and vacated Appellant's life-without-parole sentence and remanded his case for resentencing. Before a resentencing hearing was held, however, the General Assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders and extended parole eligibility to juvenile offenders. On remand, the circuit court sentenced Appellant under the FSMA to life in prison with parole eligibility after thirty years. The Supreme Court reversed, holding (1) because Appellant committed his crime before the effective date of the FMSA, the penalty provisions of the Act did not apply to him; and (2) Appellant was no longer serving a sentence to which parole eligibility could attach. View "Elliott v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the judgment of the trial court dismissing Appellant's pro se petition and two amendments in which he sought a writ of audita querela, thus rendering moot Appellant's pro se motion in which he sought to file his reply brief belatedly, holding that Appellant was not entitled to relief.Appellant was convicted of furnishing prohibited articles. Appellant later filed his petition and amendments seeking a writ of audita querela. The trial court dismissed Appellant's petition and amendments on the ground that the writ of audita querela is not recognized and, therefore, the court was without jurisdiction to modify the judgment. The Supreme Court dismissed Appellant's appeal, holding that he could not prevail on appeal because, although the trial court had jurisdiction to provide relief through a writ of error coram nobis, Appellant stated no basis for issuance of the writ. View "Gonder v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of premeditated and deliberate capital murder and sentencing him to life imprisonment without parole for each murder, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held that the circuit court (1) did not abuse its discretion or deprive Appellant of his constitutional right to present a defense by excluding evidence that Appellant argued linked another person to the crimes; and (2) did not abuse its discretion in allowing testimony concerning what a person could see with a telescopic sight mounted on Appellant's rifle. View "Barefield v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition to proceed in forma paupers in a habeas proceeding, holding that the circuit court did not abuse its discretion in finding that Appellant should not be permitted to proceed at public expense.In denying the petition for writ of habeas corpus the circuit court found that the petition did not contain a colorable cause of action. The Supreme Court dismissed Appellant's appeal, which rendered moot Appellant's motion for extension of time to file his brief-in-chief, holding that Appellant's assertions and allegations were either not cognizable in habeas proceedings or brought without factual substantiation or development. View "Watson v. Kelley" on Justia Law

The Supreme Court dismissed the State's appeal from the circuit court's decision to dismiss criminal charges against Defendant for violation of his speedy-trial rights, holding that Ark. R. App. P.-Crim. 3(d) prohibited this Court from considering the appeal.Defendant was arrested based on allegations that he had sexually assaulted his children. After the trial court granted the State six continuances Defendant filed a motion to dismiss for violation of his speedy-trial rights. The circuit court granted the motion. The State appealed, arguing that the case turned purely on an issue of law. The Supreme Court disagreed, holding that Rule 3(d) did not allow this Court to consider the State's appeal because the circuit court's decision to dismiss the charges turned upon the specific facts of this particular case. View "State v. Jones" on Justia Law