Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition to proceed in forma pauperis, holding that the circuit court did not abuse its discretion in finding that Appellant should not be permitted to proceed.The circuit court denied Appellant’s request for pauper status because it found the underlying writ of habeas corpus did not contain a colorable cause of action. Specifically, the circuit court found that Appellant had established that he was indigent, but he did not raise a cognizable claim. The Supreme Court affirmed, holding that the decision to deny Appellant’s request for pauper status was proper where Appellant’s habeas petition clearly failed to state a colorable cause of action because it did not state sufficient nonconclusory facts to support cognizable claims. View "Breeden v. Kelley" on Justia Law

The Supreme Court dismissed this appeal from an order dismissing Appellant’s petition to correct a sentence imposed in an illegal manner under Ark. Code Ann. 16-90-111, rendering moot Appellant’s pro se motion requesting an extension of time in which to file his brief, holding that it was clear Appellant could not prevail on appeal.The trial court found that Appellant’s sentence was within the statutory range and not illegal and that Appellant’s petition was untimely. The Supreme Court held that the denial of relief was not clearly erroneous, holding that the petition was untimely and that Appellant’s claims were meritless. View "Jackson v. State" on Justia Law

The Supreme Court denied Petitioner’s second petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis, holding that there was no merit to Petitioner’s allegations and that Petitioner did not exercise due diligence in bringing his claims.In 2009, Petitioner was found guilty of the rape of a five-year-old girl. In his claims for issuance of the writ, Petitioner argued that the prosecutor committed misconduct and violated Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petition, holding (1) Petitioner failed to establish a Brady violation; and (2) Petitioner failed to exercise due diligence in bringing this second coram nobis petition. View "Henington v. State" on Justia Law

The Supreme Court affirmed the trial court’s dismissal of Appellant’s petition for postconviction relief under Ark. R. Crim. P. 37.1, holding that Appellant failed to challenge the basis for the circuit court’s dismissal of his petition on appeal.The trial court dismissed Appellant’s postconviction petition without addressing the merits, finding that Appellant had failed to file it within the time allotted under Rule 37. On appeal, Appellant did not argue that the trial court erred in ruling that his petition was untimely filed. The Supreme Court affirmed because Appellant failed to challenge the trial court’s finding that his petition was not timely. View "Friar v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of rape and sentencing him to a term of life imprisonment, holding that the court did not abuse its discretion in granting the State’s motion in liming to exclude evidence that the victim had filed a lawsuit against the owners of an apartment complex where the rape occurred.On appeal, Defendant argued that evidence of the victim’s civil suit was relevant to the issues of bias and credibility because a guilty verdict in the criminal case might aid the victim’s recovery in the civil matter. The Supreme Court affirmed, holding that Defendant’s failure to make a proffer of excluded evidence precluded appellate review. View "Sharp v. State" on Justia Law

Petitioner’s petition for writ of mandamus in which he requested that the circuit judge assigned to his criminal case to enter an order on a petition for postconviction relief, holding that Petitioner failed to show a clear and certain right to the relief.The Supreme Court held that because the judge responded indicating that the matter was under consideration and proceeding, Petitioner failed to show that the delay in this case was one extending beyond the time reasonably necessary to dispose of the matter. Therefore, relief was not merited on the petition. View "Wallace v. Honorable Leon Johnson" on Justia Law

The Supreme Court affirmed Defendant’s convictions of kidnapping, abuse of a corpse, and capital murder and his sentence of death, holding that there were no errors in the proceedings below that were prejudicial to Defendant.Specifically, the Court held (1) no prejudicial error occurred when the circuit court permitted the jury to consider the death of the victim’s unborn child as an aggravating circumstance; (2) the circuit court did not abuse its discretion when it permitted the prosecution to present rebuttal testimony; (3) the circuit court did not manifestly abuse its discretion in allowing the State to make certain comments during the penalty-phase rebuttal closing argument; (4) the circuit court properly instructed the jury; and (5) the jury did not act arbitrarily when it chose not to find Defendant’s history, or lack thereof, of criminal activity to be worth of mitigating the punishment for his crime. View "Smith v. State" on Justia Law

The Supreme Court dismissed the State’s appeal from the circuit court’s order granting Defendant’s motion to dismiss the charges against her based on a speedy-trial violation, holding that this was not a proper State appeal under Ark. R. App. P.-3(d).Defendant was convicted of thirty-one counts of misdemeanor animal cruelty in district court. Defendant appealed her convictions to the circuit court. Defendant later moved to dismiss the charges against her based on speedy-trial grounds. The circuit court found that Defendant’s right to a speedy trial had been violated and dismissed the charges against her. The State appealed. The Supreme Court granted Defendant’s motion to dismiss, holding that the State’s appeal was not authorized under Rule 3. View "State v. Seigel" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant’s petition for writ of habeas corpus, holding that the circuit court did not err in rejecting Appellant’s claim that he was subject to double jeopardy and that the sentence imposed on him was illegal.Appellant pleaded guilty to rape and incest. Appellant filed a habeas petition arguing that his sentence was illegal because he was found guilty of both rape and incest and because the judgment-and-commitment order required that he complete special program for sexual offenders while in prison. The Supreme Court held (1) Appellant did not meet hid burden of establishing that his double-jeopardy claim was cognizable in a proceeding for a writ of habeas corpus; and (2) the circuit court did not err in finding that the judgment-and-commitment order did not include a special condition of incarceration as part of Appellant’s sentence. View "Sims v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of first-degree murder and sentence of life imprisonment, holding that there was no abuse of discretion or error in the proceedings below.Specifically, the Court held (1) the circuit court did not err by denying Defendant’s motions to exclude testimony of an expert witness, an agent of the FBI, and Defendant’s motion for mistrial for use of the witness’s testimony for alleged discovery violations because Defendant failed to establish a Brady violation; and (2) Defendant failed to preserve for appeal his argument that the circuit court erred in allowing the admission of “content” based text messages in response to a subpoena without a warrant. View "Duck v. State" on Justia Law