Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s dismissal of Appellant’s petition for judicial review under the Arkansas Administrative Procedure, declaratory relief, and petition for writ of mandamus, holding that the circuit court did not err in denying relief.In his petition, Appellant challenged the decision of the Arkansas Board of Parole denying him parole for an additional year. The circuit court held that Appellant failed to state a claim establishing a constitutional violation that would allow for judicial review or injunctive relief. The court denied the petition for writ of mandamus, concluding that the Board’s decision was discretionary. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in finding that Appellant’s speculative claim could not survive a motion to dismiss; and (2) did not err in denying the writ of mandamus. View "Null v. Arkansas Parole Board" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a sentence of life with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), 2017 Ark. Acts 2165, holding that the circuit court erred in applying the FSMA to Appellant’s case.Appellant was sixteen years old when he committed the crimes leading to his convictions for capital murder and theft of property. Appellant received a sentence of life imprisonment without parole for capital murder. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant petitioned for writ of habeas corpus. The circuit court granted the petition, vacated Appellant’s sentence, and remanded for resentencing. Before the circuit court could conduct a Miller hearing, the General Assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders. The State then filed a motion for resentencing under the FSMA. The circuit court relied on the FSMA’s provisions in resentencing Appellant to life with the possibility of parole after thirty years. The Supreme Court reversed, holding that because Appellant’s sentence had been vacated before the FSMA was enacted, the circuit court erred in applying the FSMA to Appellant’s case. The court remanded the case for a Miller hearing. View "Ray v. State" on Justia Law

The Supreme Court treated Petitioner’s pro se motion for rule on clerk seeking to proceed with an appeal as a motion for belated appeal and denied the motion, holding that Petitioner’s petition was wholly without merit, and Petitioner could not prevail on appeal.Petitioner filed a pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, which the trial court denied. Petitioner then filed this motion. The Supreme Court denied the motion, holding that Petitioner’s sentence was clearly within the prescribed statutory range and was not illegal, and therefore, the trial court’s denial of his most recent claim for relief under section 16-90-111 was not in error. View "Redus v. State" on Justia Law

The Supreme Court denied Petitioner’s petition to reinvest jurisdiction in the trial court to proceed with a petition for writ of error coram nobis and Petitioner’s motion for default judgment, holding that Petitioner was not entitled to relief.Petitioner was convicted of second-degree murder. After his conviction was affirmed, Petitioner filed the instant petition seeking permission from the Supreme Court to proceed in the trial court with a petition for writ of error coram nobis, arguing that trial error resulted in the imposition of an illegal sentence. Petitioner later filed a motion for default judgment. The Supreme Court denied both filings, holding that the factual basis for Petitioner’s claims was insufficient to go beyond allegations of a defective information and trial error, which do not implicate the facial validity of a trial court’s judgment or jurisdiction. View "Rainer v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing Appellant’s petition for writ of error coram nobis, holding that the circuit court did not err in denying the writ of error coram nobis because Appellant did not plead facts to show coercion.On appeal, Appellant argued that the circuit court erred in determining that his allegation that counsel promised to help him get a pardon if he pleaded guilty was insufficient to meet the burden of proving he was coerced. The Supreme Court affirmed, holding (1) the trial court did not err in finding that Appellant’s allegation of coercion did not rise to the level of coercion that is required in the context of a writ of coram nobis; and (2) the circuit did not err in finding that Appellant’s claim was more akin to an ineffective assistance of counsel claim, which was not cognizable in an error coram nobis proceeding. View "Love v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from an order denying his pro se petition for writ of mandamus and found that the motion for modification of that order was moot, holding that Appellant’s notice of appeal was untimely.Appellant filed his mandamus petition against the chairman of the Arkansas Parole Board and a parole officer and filed a subsequently motion for enforcement of statute that contained arguments also raised in petition to the circuit court. The Supreme Court dismissed Appellant’s petition, holding that it was untimely and did not extend the time for filing his notice of appeal. View "Chestang v. Mays" on Justia Law

The Supreme Court reversed Appellant’s sentence of life imprisonment with the possibility of parole imposed in connection with his conviction for one count of capital murder, holding that the circuit court erred in applying the Fair Sentencing of Minors Act of 2017 (FSMA), 2017 Ark Acts 2615, to Appellant’s case.Appellant was fifteen years old at the time of the offense. Appellant was originally sentenced to life without the possibility of parole, but following Miller, the circuit court granted Appellant’s petition for writ of habeas corpus, vacated his sentencing order and remanded the case for resentencing. The circuit court sentenced Appellant to life imprisonment with the possibility of parole after thirty years based on the FSMA, holding that the FSMA applied retroactively. The Supreme Court reversed, holding (1) the circuit court erred when it retroactively applied the penalty and parole provisions of the FSMA when resentencing Appellant; and (2) Appellant was entitled to a hearing to present evidence pursuant to Miller v. Alabama, 567 U.S. 460 (2012), for consideration and sentencing within the discretionary range for a Class Y felony. View "Segerstrom v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s petition for a writ of habeas corpus, holding that because none of Appellant’s arguments provided evidence of probable cause to believe that Appellant was being illegally detained, the circuit court did not clearly err in dismissing the petition.Specifically, the Court held (1) the circuit court did not err in holding that Appellant’s claims were not appropriate for resolution in the habeas process; (2) the judgment and commitment order under which Appellant was committed was not void or defective; (3) Appellant’s third point was an evidentiary error claim that did not call into question the legality of the sentence or the jurisdiction of the circuit court; and (4) Appellant’s confinement did not violate his due process rights. View "Conley v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s petition to reinvest jurisdiction in the trial court so that he may file a petition for writ of error coram nobis in his criminal case, holding that Petitioner’s claim did not establish a ground for the writ and that Petitioner did not exercise due diligence in bringing the claim.In his petition, the third such petition filed in the Supreme Court, Petitioner argued that the State violated Brady v. Maryland, 373 U.S. 83 (1963), by withholding certain evidence. The Supreme Court denied relief, holding (1) Petitioner’s claims were not sufficient to overcome the presumption that the judgment of conviction was valid; and (2) Petitioner was not diligent in bringing this proceeding. View "Makkali v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from an order denying his pro se petition for writ of error coram nobis, holding that the the Court lacked jurisdiction to consider the appeal.Appellant lodged his appeal from a January 25, 2018 order denying his pro se petition fro writ of error coram nobis on February 28, 2018. In accordance with Ark. R. App. P.-Crim. 17, Appellant was required to file the notice of appeal no later than February 26, 2018. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the notice of appeal was not timely filed and that no exception to the filing deadline for a notice of appeal was applicable. View "Mills v. State" on Justia Law