Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), holding that Appellant was entitled to a new sentencing hearing based on this Court’s recent decision in Harris v. State, 547 S.W.3d 64.Appellant received a mandatory sentence of life imprisonment without parole for a crime he committed when he was seventeen years old. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant filed a petition for a writ of habeas corpus. The circuit court granted the writ, vacated Appellant’s life without parole sentence, and remanded his case to the circuit court for resentencing. Before the resentencing hearing was held, 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. The circuit court proceeded to sentence Appellant under the new penalty provisions of the FSMA. The Supreme Court reversed, holding that because Appellant committed his crime before the effective date of the FSMA, the penalty provisions of the Act did not apply to him. View "Howell v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order granting Appellees’ motion to dismiss Appellant’s pro se petition for writ of mandamus and complaint for conversion but modified it as a dismissal without prejudice and reversed the circuit court’s designation of the dismissal as a strike, holding that the circuit court lacked jurisdiction to consider the merits.Appellant, an inmate in the Arkansas Department of Correction, initiated a number of legal actions seeking to obtain crime lab files related to his conviction. Appellant then filed this petition and complaint seeking a writ to compel Appellees to release the contents of his crime lab file and monetary damages for conversion of the file. The circuit court dismissed the action with prejudice and designated the dismissal as a strike under Ark. Code Ann. 16-68-607. The Supreme Court held (1) because Appellant failed to timely perfect service on Appellees, the circuit court properly granted Appellees’ motion to dismiss, but the dismissal should have been without prejudice; and (2) upon determining that summons and service of process were insufficient in this case, the court lacked jurisdiction to designate the dismissal as a strike pursuant to section 16-68-607. View "Davis v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s petition for writ of mandamus filed in the Desha County Circuit Court, holding that the circuit court had no jurisdiction below.Petitioner was an inmate serving a life sentence in the custody of the Arkansas Department of Correction (ADC). Appellant filed a petition for writ of mandamus seeking to compel production of forensic test results related to his murder conviction. The crime lab mailed Petitioner his file. Upon receipt of the file, however, ADC Chief Legal Counsel James B. DePriest determined that the file contained material prohibited by ADC’s contraband policies and confiscated the package. Petitioner then brought this action requesting that DePriest be compelled to release the file. The circuit court denied the petition because DePriest was not a named party and had not been served. The Supreme Court affirmed, holding that the circuit court was correct to deny Petitioner’s petition due to this procedural and jurisdictional defect. View "Davis v. Deen" on Justia Law

The Supreme Court reversed Appellant’s conviction for first-degree murder, for which she was sentenced to life imprisonment, holding that the trial court violated Appellant’s fundamental right to a public trial by closing the courtroom to the public during the testimony of a State witness.For her first point on appeal, Appellant argued that the closure of the courtroom during the testimony of the State witness violated her constitutional right to a public trial. At issue on appeal was whether the test set forth in Waller v. Georgia, 467 U.S. 39, 48 (1984), for determining when the right of an accused to a public trial may give way to other rights or interests was met. The Supreme Court held that the trial court did not make the findings necessary to support the closure, and therefore, the case must be remanded for a new trial. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed Appellant’s conviction of capital murder, first-degree battery, and aggravated residential battery, holding that no prejudicial error occurred during the proceedings below.Before trial, Appellant filed a motion in limine to exclude any prior bad acts or altercations between Appellant and Lashundra Wilson, the victim’s mother. At a pretrial hearing, the State agreed with Appellant’s motion in limine regarding prior altercations between Appellant and Wilson. At trial, Wilson spoke of having a black eye while she was questioned about her relationship with Appellant. The circuit court denied Appellant’s motion for mistrial and instead admonished the jury to disregard the statement as nonresponsive. On appeal, Appellant argued that the circuit court erred when it denied his motion for mistrial. The Supreme Court disagreed, holding that Defendant did not demonstrate unfair prejudice because the instruction cured any error. View "McDaniel v. State" 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 of Minors Act (FSMA), holding that Appellant was entitled to a new sentencing hearing based on the Supreme Court’s recent decision in Harris v. State, 547 S.W.3d 64.In 2000, Appellant was convicted of capital murder for a crime that he committed when he was seventeen years old. Appellant received a mandatory sentence of life imprisonment without parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant filed a petition for a writ of habeas corpus. The circuit court granted the writ, vacated Appellant’s sentence, and remanded Appellant’s case for resentencing. Before Appellant’s resentencing hearing was held, 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. Thereafter, the circuit court resentenced Appellant to life imprisonment with the possibility of parole after thirty years pursuant to the new penalty provisions of the FSMA. The Supreme Court reversed, holding that because Appellant committed the crime before the effective date of the FSMA, the penalty provisions of the FSMA did not apply to him. View "Howell v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s petition for postconviction relief pursuant to Ark. R. Crim. P. 37, holding that the circuit court did not err in summarily denying Appellant’s claim that his trial counsel was ineffective and that appellate counsel was not ineffective.Specifically, the Supreme Court held (1) contrary to Appellant’s argument on appeal, Appellant’s trial counsel did not provide ineffective assistance when he compared Appellant’s case to the O.J. Simpson case; and (2) appellate counsel was not ineffective by failing to challenge the sufficiency of the evidence on direct appeal. View "Woods v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s petition for writ of habeas corpus, holding that Appellant stated no ground for relief cognizable in a habeas proceeding.On appeal, Appellant argued that there were multiple errors committed in his trial and in the court of appeals’ decision in his direct appeal, that the Supreme Court erred in denying his petition for review, and that the circuit court erred in holding that his petition was not timely filed under Ark. R. Crim. P. 37.1. The Supreme Court affirmed the circuit court’s order, holding that Appellant’s petition stated no claim for relief that was within the purview of a habeas corpus proceeding, and therefore, the habeas petition was subject to denial on that basis. View "Colton v. Kelley" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for postconviction relief filed under Ark. R. Crim. P. 37, holding that the circuit court’s decision to deny the petition was not clearly erroneous.Appellant was convicted of first-degree murder and possession of a firearm and was sentenced to a term of life imprisonment. Appellant’s convictions and sentences were affirmed. Appellant later filed a petition for postconviction relief under Rule 37, arguing, among other things, that his trial counsel was ineffective for failing to present proper jury instructions on extreme-emotional-disturbance manslaughter. On remand, the circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant was not entitled to a jury instruction on extreme emotional disturbance, and therefore, Appellant was not entitled to postconviction relief. View "Douglas v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for two counts of capital felony murder and one count of aggravated robbery, holding that there was sufficient evidence to support the verdict.On appeal, Defendant argued that the circuit court erred in denying his motion for directed verdict, contending that there was insufficient corroboration of accomplice testimony to sustain the burden of proof for all charges. The Supreme Court affirmed, holding that there was sufficient corroboration of the accomplice testimony, and the evidence was sufficient to support the jury’s verdict on all charges. View "Lawshea v. State" on Justia Law