Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for writ of habeas corpus on the grounds that Appellant failed to establish that his sentence was facially illegal or that the trial court lacked jurisdiction, holding that Appellant failed to present any evidence establishing probable cause for issuance of the writ.Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant later filed a writ of habeas corpus alleging that he was being held pursuant to an invalid conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s claims were without merit and that Appellant was not entitled to a hearing. View "Grimes v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion for belated appeal and rule on clerk seeking to proceed with a belated appeal of the judgment pursuant to Arkansas Rule of Appellate Procedure-Criminal 2(e), holding that the trial court did not err in finding that Petitioner did not articulate a his wish to file an appeal.Petitioner was convicted of sexual assault in the second degree. Petitioner later filed this motion arguing that his trial counsel failed to pursue a timely appeal on his behalf. The Supreme Court remanded the matter for an evidentiary hearing. On remand, after a hearing, the trial court found that Petitioner did not articulate a desire to appeal within the time limit allowed for counsel to file a timely notice of appeal. View "Beene v. State" 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 of 2017 (the Act), holding that Appellant was entitled to resentencing in accordance with the Court’s decision in Harris v. State, 547 S.W.3d 64.In 1983, Appellant pled guilty to capital murder. Appellant was seventeen years old at the time of the murder and received a mandatory sentence of life without parole. Following the United States Supreme Court’s decision in Miller v. Alabama, 467 U.S. 460, 479 (2012), Appellant filed a petition for habeas corpus arguing that his sentence was unconstitutional. The circuit court granted the petition, vacated the sentence, and remanded Appellant’s case for resentencing. Although Appellant’s sentence had been vacated before the Act was enacted, the circuit court relied on the Act’s provision in resentencing him to life imprisonment with the possibility of parole after thirty years. The Supreme Court reversed, holding (1) based on this Court’s decision in Harris, the circuit court erred in applying the Act to Appellant’s case; and (2) Appellant was entitled to a hearing to present Miller evidence for consideration upon resentencing. View "Robinson 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 Appellant’s arguments lacked merit.Appellant was convicted of first-degree murder and aggravated robbery and sentenced to life imprisonment for each conviction. In his petition for writ of habeas corpus, Appellant argued that Graham v. Florida, 560 U.S. 48 (2010), rendered his life sentence for aggravated robbery unconstitutional because he was a minor at the time of the offense and that Miller v. Alabama, 567 U.S.460 (2010, and Montgomery v. Louisiana, 136 S. Ct. 718 (2016) precluded his sentence even for his homicide offense. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s Miller-based argument was without merit; and (2) Graham had no application to Appellant’s case. View "Early v. Kelley" on Justia Law

The Supreme Court affirmed the denial of Appellant’s pro se petition for leave to proceed in forma pauperis on a petition for writ of habeas corpus, holding that it was clear from the record that Appellant’s cause of action could not proceed as a matter of law.The circuit court found that Appellant had presented sufficient evidence to establish that he was indigent but that he failed to allege a matter cognizable in a habeas petition and had not presented a colorable cause of action. The Supreme Court affirmed, holding that Appellant did not establish a basis for finding that a writ of habeas corpus should issue. View "Timmons v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s second pro se petition and supplemental petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner did not meet his burden of demonstrating that the State withheld material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963).Defendant was convicted of possession of cocaine and resisting arrest. In the instant petition, Petitioner asserted that the time of his plea and arraignment, he was unaware that his arrest warrant had been recalled, in violation of Brady. The Supreme Court denied relief, holding that Petitioner failed to meet his burden of proof or state facts sufficient to establish that the State suppressed evidence or that the evidence was exculpatory in nature. View "Rice v. State" on Justia Law

The Supreme Court granted Petitioner’s petition to reinvest the circuit court with jurisdiction to consider his petition for writ of error coram nobis or other relief, holding that that Petitioner stated sufficient grounds for the Court to find that his writ may be meritorious.Petitioner was convicted of first-degree murder and sentenced to life imprisonment. In his coram nobis petition, Petitioner argued that expert hair-comparison testimony at his trial was not meaningfully different from hair-comparison testimony in other cases wherein the Supreme Court reinvested jurisdiction in the circuit court. Therefore, Petitioner argued, this Court should follow that precedent in this case. The Supreme Court granted the petition, holding that where the expert’s testimony contained one or more of the same errors as those identified in Strawhacker v. State, 500 S.W.3d 716 (Ark. 2016), and Pitts v. State, 501 S.W.3d 803 (Ark. 2016), reinvesting jurisdiction in the circuit court was appropriate. View "Martin 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 the circuit court did not err in denying the petition because the charges did not violate double jeopardy.Appellant sent an email to an undercover police officer with an attachment containing thirty photographs depicting child pornography. Appellant pleaded guilty to thirty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. Appellant later filed a petition for writ of habeas corpus alleging that his convictions on twenty-nine of the thirty counts violated double jeopardy because he sent only one email with one attachment. The circuit court denied relief. The Supreme Court affirmed, holding that each photograph that was distributed could support a separate charge, and the fact that the thirty photographs were attached to the email in a single file was not relevant in this case. View "Pelletier v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree murder and sentencing him to a term of life imprisonment, holding that substantial evidence supported the jury’s verdict that Appellant committed the offense.On appeal, Appellant argued as his sole point that the circuit court erred in denying his motion for directed verdict. The Supreme Court affirmed, holding that, viewing the evidence in the light most favorable to the State, the evidence presented at trial was sufficient to sustain Appellant’s first-degree murder conviction. View "Arnold v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1 without holding an evidentiary hearing, holding that the petition and record conclusively showed that Appellant was entitled to no relief.In his petition for postconviction relief, Petitioner alleged that trial counsel was ineffective in seven separate instances. The trial court denied the petition without an evidentiary hearing, concluding that Petitioner failed to allege explicit grounds for postconviction relief. The Supreme Court affirmed, holding that there was no merit in Petitioner’s arguments and that Petitioner was not entitled to postconviction relief. View "Gordon v. State" on Justia Law