Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed Appellant’s conviction of first-degree murder and sentence of life imprisonment, holding that there was no reversible error in the proceedings below.On appeal, Appellant argued that there was insufficient evidence to sustain his first-degree murder conviction and that the circuit court abused its discretion by excluding a toxicology report showing the presence of a controlled substance in the victim’s body. The Supreme Court held (1) substantial evidence supported Appellant’s first-degree murder conviction; and (2) the circuit court did not abuse its discretion when it concluded that the probative nature of the toxicology report would be substantially outweighed by the danger of unfair prejudice. View "Drennan 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 and a motion for appointment of counsel, holding that Petitioner did not establish a ground for the writ.In his petition, Petitioner argued that the trial court and the State violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose that a certain juror was biased. Petitioner also filed a motion for appointment of counsel. The Supreme Court held (1) Petitioner failed to demonstrate a Brady violation because he did not show that some fact was hidden from the defense; and (2) the denial of Petitioner’s petition rendered his motion for appointment of counsel moot. View "Goins v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the circuit court’s order dismissing Appellant’s complaint for declaratory and injunctive relief against the Director of the Arkansas Department of Correction, holding that the circuit court (1) properly dismissed Appellant’s claim that executing him after twenty-five years in solitary confinement would be cruel and unusual punishment prohibited by the Eighth Amendment; but (2) erred in dismissing Appellant’s claim that Ark. Code Ann. 16-90-506(d)(1) violates his due process rights under the United States and Arkansas Constitutions by vesting sole discretion in the Director to determine whether a prisoner is competent to be executed. The Court remanded the case to the circuit court for further proceedings consistent with this opinion. View "Greene v. Kelley" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Petitioner’s petition for a writ of error coram nobis, holding that Petitioner’s allegations did not provide a basis for the issuance of the extraordinary writ or were not cognizable in an error coram nobis proceeding.Specifically, the Court held (1) the arguments Petitioner raised for the first time on appeal will not be addressed; (2) Petitioner’s allegations that certain witnesses were coerced into providing statements implicating Petitioner did not fit within the recognized categories for coram nobis relief and did not otherwise provide a basis for the issuance of the writ; and (3) by pleading guilty, Petitioner waived any claim that he was not guilty of the charges. View "Hall v. State" on Justia Law

The Supreme Court reversed the circuit court’s dismissal of Plaintiff’s complaint against several individuals (collectively, the State) seeking injunctive and declaratory relief and challenging his competence to be executed, holding that Ark. Code Ann. 16-90-506(d)(1) is unconstitutional and violates the Due Process Clause of both the United States Constitution and the Arkansas Constitution.Plaintiff, an inmate scheduled to be executed, argued that the statute unconstitutionally delegates the competence inquiry to the Director of the Arkansas Department of Correction and denies an incompetent prison access to the court to obtain an evidentiary hearing to determine whether he is competent to be executed. The circuit court granted the State’s motion to dismiss the complaint, concluding that Plaintiff failed to state a claim. The Supreme Court reversed, holding (1) Plaintiff had standing to bring this action; (2) the constitutional issues were preserved for appellate review; and (3) section 16-90-501(d)(1) is unconstitutional on its face and violates due process guarantees. View "Ward v. Hutchinson" on Justia Law

The Supreme Court granted Appellant’s petition for rehearing and issued this opinion reversing Appellant’s three rape convictions and remanded for a new trial or further proceedings, holding that the circuit court erred by not allowing Appellant to impeach one of the victims with a crime of dishonesty, and the error was prejudicial.The Supreme Court previously affirmed Appellant’s convictions and sentences. Appellant petitioned for rehearing, arguing, inter alia, that the circuit court erred by not allowing him to impeach L.W., one of his three alleged victims, with a prior theft conviction. The Supreme Court reversed the convictions, holding (1) the evidence Appellant sought to introduce to impeach L.W.’s credibility satisfied the requirements of Ark. R. Evid. 609, and the evidence should have been allowed; and (2) where the victims’ credibility was a major consideration for the jury, the error was not harmless. View "Rogers v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court to hold Tony Huffman, an attorney with the Arkansas Department of Human Services (DHS), and Erika Eneks, a caseworker for the Crawford County DHS Office, in contempt, holding that the court’s decision was supported by substantial evidence and reasonable inferences therefrom.The Supreme Court held (1) with regard to both Huffman and Eneks, the circuit court’s punishment consisted of eight hours of community service and a one-page paper, an unconditional penalty treated by the law as “criminal” contempt; (2) the conduct in question was “direct” contempt where it occurred in the presence of the circuit judge; and (3) as to both individuals, the circuit court’s decision was supported by substantial evidence and reasonable inferences therefrom. View "Arkansas Department of Human Services v. Dowdy" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s petition seeking a writ of error coram nobis, holding that the trial court’s findings were supported by the record, and the trial court did not abuse its discretion by declining to issue the writ.Appellant entered a negotiated plea of nolo contendere to charges of manslaughter, manufacture of a controlled substance, abuse of a corpse, and tampering with physical evidence. In his coram nobis petition, Appellant alleged that he was coerced into entering the plea. The trial court denied the petition on several grounds. The Supreme Court affirmed the denial of relief, holding that Appellant had not shown an abuse of the trial court’s discretion in declining to issue the writ. View "Davis v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal of an order denying him pauper status so that he could proceed with a petition for writ of habeas corpus to challenge his convictions for capital murder and aggravated robbery, holding that the circuit court correctly found that Appellant failed to set out a colorable cause of action in his proposed habeas petition, and therefore, Appellant could not prevail on appeal.In his habeas petition, Appellant alleged that the State failed to meet its burden of proof beyond a reasonable doubt, the trial judge erred and abused his discretion, and his trial attorney and appellate counsel were ineffective. The circuit court found that Appellant failed to support a claim cognizable in habeas proceedings. The Supreme Court agreed, holding that Appellant petition clearly failed to state a colorable cause of action. View "Gardner v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s petition asking the Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to make sufficient allegations to warrant coram nobis relief.Petitioner was convicted of aggravated robbery, theft of property, and first degree sexual abuse. In his coram nobis petition, Petitioner alleged that the prosecutor during his criminal trial withheld evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), which would have established that his confession to the robberies was coerced. The Supreme Court denied relief, holding that because Petitioner’s arguments pertained to matters that were wholly contained within the record and known to the defense at the trial, Petitioner’s allegations did not warrant reinvesting jurisdiction in the circuit court to consider a coram nobis petition. View "Bunch v. State" on Justia Law