Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for a writ of habeas corpus, holding that the circuit court did not err in dismissing the petition.Appellant was convicted for a string of robberies he committed when he was seventeen years old. In his habeas corpus petition, Appellant argued that the 240-year cumulative sentence he was serving was a de facto life sentence in violation of Graham v. Florida, 560 U.S. 48 (2010) and that he sentence was grossly disproportionate to his crimes. The circuit court denied the petition. The Supreme Court affirmed, holding (1) where Appellant had multiple sentences and no individual sentence was a life sentence, Graham did not apply; and (2) Appellant’s argument that his sentence was grossly disproportionate to the crimes he committed was not preserved for review. View "Proctor v. Kelley" on Justia Law

The Supreme Court reversed Defendant’s conviction of possession of methamphetamine, holding that the circuit court erred by denying Defendant’s motion to suppress because the search of Defendant’s wallet violated the Fourth Amendment of the United States Constitution.Defendant was arrested and charged with possession of methamphetamine after the arresting officer discovered the drug in Defendant’s wallet. In his suppression motion, Defendant argued that the officer did not have a reasonable, articulable suspicion to search him for weapons and lacked probable cause or reasonable suspicion to search his wallet. The Supreme Court agreed, holding that the officer did not have probable cause to search Defendant’s wallet, and because Defendant did not consent to the search of his wallet, the search violated the Fourth Amendment. View "Shay v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant’s petition for writ of error coram nobis, holding that the circuit court did not err in dismissing the petition, limiting discovery for the evidentiary hearing, or denying Appellant’s motion for judicial recusal.Appellant was convicted of capital murder and sentenced to death. Appellant later petitioned the Supreme Court to reinvest jurisdiction in the circuit court to allow him to seek a writ of error coram nobis. The Supreme Court revinested the circuit court with jurisdiction to consider Appellant’s claims of Brady violations. After a hearing, the circuit court dismissed Appellant’s petition for writ of error coram nobis. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate Brady violations, the circuit court did not err in dismissing Appellant’s petition for writ of error coram nobis; (2) the circuit court did not abuse its discretion in limiting discovery; and (3) the circuit court did not abuse its discretion in denying Appellant’s motion for recusal. View "Isom v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se second petition to reinvest jurisdiction with the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate that the writ should issue and that several of Petitioner’s claims were successive.Petitioner was convicted of first-degree murder and sentenced as a habitual offender to 720 months’ imprisonment. In his second coram nobis petition, Petitioner claimed that he suffered a variety of defects in the underlying criminal proceedings, including a Brady violation. The Supreme Court denied relief, holding (1) where several of Petitioner’s claims were raised in his first coram nobis petition and were again raised here without additional facts, these arguments constituted an abuse of the writ; and (2) the one issue that Petitioner did not previously raise did not provide a basis for the issuance of this extraordinary writ. View "Smith v. State" 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 did not state a ground for the writ.In his petition, Appellant argued that the trial court and court of appeals made errors that amounted to a breakdown in both the trial and the direct-appeal proceedings and that the evidence was insufficient to sustain the judgment. The Supreme Court denied relief, holding that error by the trial court or the appellate court is not a ground to grant a writ of error coram nobis and that an attack on the sufficiency of the evidence is not within the purview of a coram nobis proceeding. View "Hall v. State" on Justia Law

The Supreme Court dismissed Appellant’s interlocutory appeal from an order of the trial court that denied his pro se motion for reconsideration of the order that denied his motion to file an overlength amendment to his postconviction relief petition pursuant to Ark. R. Crim. P. 37.1, holding that the order that denied the motion for reconsideration was not a final, appealable order.In his Rule 37.1 petition, Appellant challenged the judgment of conviction entered in his criminal case and filed a motion seeking leave of the court to file an overlength amendment to the Rule 37.1 petition. After the trial court denied the motion, Appellant filed a motion for reconsideration, which was also denied. Appellant then filed this interlocutory appeal. The Supreme Court dismissed the appeal, holding that Petitioner was not permitted to proceed with an interlocutory appeal of the denial of motions filed in the course of a Rule 37.1 proceeding. View "Robinson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition for leave to proceed in forma pauperis in which he sought to proceed with a petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition because Appellant failed to raise a claim that can be recognized in a habeas proceeding.In denying the in forma pauperis petition, the circuit court found that Appellant had presented sufficient evidence to establish that he was indigent but failed to set forth a colorable cause of action. The Supreme Court affirmed, holding that Appellant’s claims of an involuntary plea or improper plea procedures were not properly addressed in a habeas proceeding. View "Mack v. Kelley" 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 was not entitled to relief.Petitioner, who was convicted of multiple counts of aggravated robbery, alleged in his petition that his sentence was illegally enhanced because the prosecutor withheld evidence supporting his habitual-offender status in violation of Brady v. Maryland, 373 U.S. 83 (1963). Petitioner also filed a pro se motion for sanctions to be placed upon the office of the attorney general. The Supreme Court denied the petition, holding that Petitioner failed to make sufficient allegations to warrant coram nobis relief and that coram nobis relief is not an available remedy for the purpose of seeking a reduction in a sentence. View "Bunch v. State" on Justia Law

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