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 because Appellant had his sentence vacated pursuant to Miller v. Alabama, 567 U.S. 460 (2012), Appellant was not subject to sentencing under the FSMA.Appellant was convicted of capital murder for an offense he committed when he was less than eighteen years of age. The jury sentenced Appellant to life imprisonment without the possibility of parole. Appellant's sentence was later vacated pursuant to Miller. Before the resentencing hearing, the Arkansas General Assembly passed the FSMA. The circuit court sentenced Appellant under the FSMA to a term of life imprisonment with the possibility of parole after thirty years. After the circuit court's order, the Supreme Court decided Harris v. State, 547 S.W.3d 64, in which the Court determined that individuals who had their sentences vacated pursuant to Miller were not subject to sentencing under the FSMA. On appeal, Appellant argued that his case should be controlled by Harris even where Harris was handed down after the circuit court's ruling. The Supreme Court agreed and remanded the case for resentencing in accordance with Harris. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's fifth pro se petition requesting permission to proceed with a petition for writ of error coram nobis in the trial court, holding that Petitioner did not satisfy any ground for granting the writ and failed to offer facts sufficient to warrant granting leave to proceed in the trial court for the writ.Petitioner was convicted of first-degree murder and sentenced to life imprisonment. In his petition, Petitioner requested permission to reinvest jurisdiction in the circuit court to file a petition for writ of error coram nobis on the grounds of prosecutorial misconduct. The Supreme Court denied the writ, holding that Petitioner's arguments in support of the writ were without merit and that Petitioner failed to demonstrate prejudice. View "Scott v. State" on Justia Law

The Supreme Court treated Defendant's motion to lodge an appeal from a judgment sentencing him to 360 months imprisonment as a motion for rule on clerk and granted the motion, holding that because Defendant's counsel never took any action to perfect the appeal, Defendant was entitled to relief.Defendant was convicted or two counts of rape. Defense counsel filed a timely notice of appeal from the judgment but never lodged the record with the clerk of court and never took any action to perfect the appeal. Defendant also filed a motion for permission to file an amended brief. The Supreme Court granted Defendant's motion to lodge an appeal on the ground that a criminal defendant cannot be denied his first appeal because counsel failed to follow mandatory appellate rules. The Court then denied the motion for permission to file an amended brief because no briefing schedule for the appeal had been set. View "Peoples v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for directed verdict and denying Appellant's motion for a mistrial, holding that the State presented sufficient evidence to convict Appellant of first-degree murder and that the circuit court did not abuse its discretion in denying the mistrial motion.After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced as a habitual offender to life imprisonment plus a fifteen-year firearm enhancement. The Supreme Court affirmed, holding (1) substantial evidence supported the jury's verdict; and (2) the circuit court did not did not err in denying Appellant's motion for mistrial after a witness alluded to Appellant's criminal history. View "McClendon v. State" on Justia Law

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 the circuit court erred in sentencing Appellant under the FSMA because Appellant committed his crime before the effective date of the FSMA.In 1996, Appellant was convicted of capital murder and received a mandatory sentence of life imprisonment without parole. Appellant was sixteen years old at the time of the crime. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant filed a petition for writ of habeas corpus. The circuit court issued the writ, vacated Appellant's sentence, and remanded the 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. The circuit court retroactively applied the FSMA to Appellant and resentenced him to life imprisonment with the possibility of parole after thirty years. The Supreme Court reversed and remanded for a resentencing hearing, holding that Harris v. State, 547 S.W.3d 64, controls this appeal and that the circuit court erred by sentencing Appellant under the FSMA. View "Miller v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentence for capital murder, unlawful discharge of a firearm from a vehicle, and terroristic act, as well as a sentence enhancement for employing a firearm in the commission of a felony, holding that no prejudicial error occurred in the proceedings below.Specifically, the Court held (1) the trial court did not err by denying Defendant's motions for directed verdict on the charges of capital murder and terroristic act, Class B felony; (2) the trial court did not prejudicially err by allowing hearsay testimony and failing to give a limiting instruction to the jury; and (3) the enhancement of Appellant's sentence for capital murder was not illegal. View "Martinez v. State" on Justia Law

The Supreme Court affirmed the circuit court’s order denying Appellant’s petition for leave to proceed in forma pauperis with a petition for declaratory judgment, holding that the underlying petition clearly failed to state a colorable cause of action.Appellant sought a declaratory judgment that the Court’s procedural rules governing postconviction relief for those inmates not under a sentence of death, Ark. R. Crim. P. 37.1-37.4, are constitutional because the rules fail to require appointment of counsel to assist a prisoner in applying for that postconviction relief. The Supreme Court held that the circuit court did not abuse its discretion in finding that Appellant should not be permitted to proceed as a pauper because the declaratory judgment petition failed to demonstrate a colorable cause of action. View "Burgie v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his petition to proceed in forma pauperis in an action seeking a writ of habeas corpus, thus declaring the motions Appellant filed in connection with the appeal moot, holding that Appellant’s claims were not cognizable in habeas proceedings.The circuit court denied Appellant’s petition to proceed in forma pauperis in an action seeking a writ of habeas corpus on the basis that Appellant failed to state a colorable cause of action. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Appellant’s petition to proceed as a pauper because the claims raised in the petition should have been raised in a timely petition for relief under Ark. R. Crim. P. 37.1. View "Smith v. Kelley" on Justia Law

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