Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant leave to proceed in forma pauperis on his petition for writ of habeas corpus, holding that the underlying habeas petition set out a claim that fell within those cognizable for the writ, yet it did not provide an adequate demonstration of probable cause to support issuance of the writ.Appellant was convicted of rape and first-degree sexual assault entered on a negotiated guilty plea and was sentenced to sixty years' imprisonment. Appellant filed a petition for writ of habeas corpus alleging that the trial court did not have the authority to enter the judgment because he did not in fact enter a guilty plea. Appellant then filed his petition for leave to proceed in forma pauperis. The circuit court denied relief, finding sufficient evidence that Appellant was indigent but that he failed to allege a matter cognizable in a petition for the writ. The Supreme Court affirmed, holding that the claims in Appellant's habeas petition were not sufficient to support his allegations of a colorable cause of action. View "Morgan v. Kelley" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's request to proceed in forma paupers on a petition for writ of habeas corpus, holding that Appellant failed to state a colorable cause of action for habeas relief.Appellant was convicted of drug-related crimes. Appellant was later convicted of additional felony offenses and sentenced as a habitual offender to life imprisonment. In the instant habeas petition, Appellant raised the same claims and factual allegations for habeas relief that he had raised previously in a habeas petition and that were rejected by this Court. The circuit court concluded that Appellant failed to state a colorable claim for habeas relief because the same claims had been previously addressed and found to be outside the purview of habeas proceedings. The Supreme Court affirmed, holding that the circuit court did not err. View "Watts v. Kelley" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's denial of his pro se petition to correct an illegal sentence, which mooted Appellant's motion for an extension of time to file his brief-in-chief, holding that that Appellant's sentence of life imprisonment was illegal.Appellant was convicted of capital murder and aggravated robbery and was sentenced to life imprisonment. In his petition to correct an illegal sentence Appellant alleged that his mandatory sentence of life imprisonment should be set aside pursuant to Miller v. Alabama, 567 U.S. 460, and Graham v. Florida, 560 U.S. 48 (2010), because he was eighteen when he committed the crimes. The circuit court denied relief. The Supreme Court dismissed the appeal, which rendered Appellant's motion moot, holding that because Appellant was an adult when he committed capital murder, his sentence of life imprisonment was not illegal. View "Burgie v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that it was clear from the face of the petition that Appellant did not substantiate with facts a ground for relief in his Rule 37.1 petition.In his petition, Appellant alleged four of his claims of ineffective assistance of counsel. The trial court denied the petition. Appellant appealed and filed a motion for an extension of time to file a reply brief in the appeal. The Supreme Court (1) affirmed the denial of Appellant's postconviction petition, holding that Appellant failed to support the four allegations that he argued on appeal were wrongfully decided by the trial court with facts to demonstrate that he suffered actual prejudice by any of counsel's alleged errors; and (2) denied the motion for extension of brief time, holding that there was no good cause to delay action on the appeal by granting leave to file a reply brief. View "Maiden v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition for a writ of error coram nobis, which mooted Appellant's motion to file a belated brief-in-chief, holding that it was clear from the record that Appellant's allegations failed state a claim for coram nobis relief.In his petition, Appellant asserted that his guilty plea was not voluntarily or intelligently entered because his counsel led him to believe that his sentence would be life imprisonment, not life imprisonment without the possibility of parole. The Supreme Court dismissed the appeal, holding that Appellant did not allege that his guilty plea resulted from any form of physical or psychological duress as required for a writ of error coram nobis in this context. View "Wade v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to reinvest jurisdiction in the trial court to consider his petition for writ of error coram nobis and to recall the Court's mandate affirming his conviction for capital murder and sentence of life imprisonment without parole, holding that Petitioner set out no basis that would support issuance of the writ or a recall of the mandate.As grounds for his petition, Petitioner alleged that the prosecutor made improper statements during his criminal trial. In an amendment to the petition, Petitioner argued that his sentence was illegal because he was eighteen years old when he committed the murder. The Supreme Court denied the petition and the amendment, holding that Petitioner failed to establish an error of fact extrinsic to the record that could not have been raised in the trial court and failed to allege any extraordinary circumstances warranting recall of the mandate. View "Muhammad v. State" on Justia Law

The Supreme Court dismissed the appeal brought by Appellant from the denial of his petition for writ of habeas corpus in which he challenged a judgment and commitment order reflecting his conviction for first-degree murder and life sentence, holding that it was clear that Appellant could not prevail on appeal.Appellant filed his petition for writ of habeas corpus in the circuit court of the county where he was incarcerated, alleging that the judgment and commitment order was facially invalid. The circuit court denied the petition. Before Appellant filed his notice of appeal he was transferred to an Arkansas Department of Correction facility in another county. The Supreme Court dismissed the appeal, holding that the circuit court did not have personal jurisdiction to issue and make returnable before itself a writ of habeas corpus to release Appellant, who was held in another county. View "Jackson v. Kelley" on Justia Law

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's petition did not establish the prejudice prong of Brady v. Maryland, 373 U.S. 83 (1963).Petitioner was found guilty of aggravated robbery, kidnapping, and theft of property. In his coram nobis petition, Petitioner alleged that the prosecution withheld evidence with respect to agreements entered into between the prosecutor and a witness for the State, in violation of Brady v. Maryland. The Supreme Court denied relief, holding that Petitioner's claim did not satisfy the prejudice prong of Brady. View "Davis v. State" on Justia Law

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