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 of 2017 (FSMA), holding that the relevant provisions of the FSMA were inapplicable to Appellant.Appellant was found guilty of capital murder for a crime he committed when he was fifteen years old. Appellant was sentenced to a mandatory term of life imprisonment without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460, 479 (2012), Appellant petitioned for a writ of habeas corpus. The circuit court vacated Appellant’s sentence and remanded for resentencing. On remand, pursuant to the FSMA, the circuit court summarily resentenced Appellant to life imprisonment with the possibility of parole after thirty years. In reversing, the Supreme Court held (1) the relevant provisions for the FSMA were inapplicable to Appellant; and (2) therefore, Appellant was entitled to a hearing to present evidence for consideration and sentencing within the discretionary range for a Class Y felony. View "Harris v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions for two counts of sexual assault in the second degree, thus rejecting Defendant’s challenges to the trial court’s decisions with respect to a pretrial motion.On appeal, Defendant argued that the trial court erred in denying his “rape-shield” motion, which sought to introduce evidence of the sexual nature of the relationship between the victim and another minor. The Supreme Court held (1) evidence of the sexual nature of the victim’s relationship with another minor was properly excluded under Ark. R. Evid. 411, and (2) the trial court’s application of rule 411 to exclude the evidence at issue did not violate Defendant’s constitutional right to present a complete defense. View "Mouton v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion to proceed with a belated appeal. The Supreme Court previously remanded the case to the circuit court with directions to hold an evidentiary hearing to determine the date and time the circuit clerk received the notice of appeal of the denial of Petitioner’s petition to correct an illegal sentence. After the circuit court conducted the hearing, the Supreme Court denied the motion, holding that because there was nothing to contradict the date stamp on the notice of appeal, it was untimely. View "Prince v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court’s dismissal of Appellant’s pro se petition for declaratory judgment and writ of mandamus challenging the Arkansas Department of Correction’s (ADC) calculation of his parole eligibility.In his petition, Appellant alleged that the ADC incorrectly included certain felony convictions in its calculation of his multiple-offender classification and therefore misclassified him as a fourth offender for purposes of parole eligibility. In addition, Appellant argued that including his 1981 convictions for burglary and robbery resulted in an ex post facto violation. The circuit court ruled that Appellant had failed to state a claim on which relief could be granted because the ADC had not erred in its calculation as to either issue. The Supreme Court held (1) there was no ex post facto violation; but (2) the ADC incorrectly included Appellant’s perjury conviction in its calculation of Appellant’s status as a habitual offender. View "Davis v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s dismissal of Appellant’s pro se petition for writ of habeas corpus, wherein Appellant alleged that his life sentence was illegal pursuant to Miller v. Alabama, 467 U.S. 460 (2012).In his petition, Appellant argued that because he was seventeen when he committed first-degree murder, his life sentence was void pursuant to Miller. The Supreme Court held (1) because Appellant’s life sentence was discretionary, the holding in Miller was not applicable and did not render Appellant’s life sentence facially illegal; and (2) because Appellant’s sentence of life imprisonment now carries with it the possibility of parole under the Fair Sentencing of Minors Act of 2017, Appellant’s contention that his sentence violated the requirements of Miller was incorrect. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s dismissal of Appellant’s petition for writ of habeas corpus, holding that the circuit court did not err when it found Appellant failed to state a ground for the writ.In 1997, Appellant pleaded guilty to first-degree murder, aggravated robbery, and other offenses. Appellant argued in the instant habeas petition that he was innocent, among other claims. The circuit court found that Appellant’s claims were not cognizable in a writ of habeas corpus. The Supreme Court affirmed, holding that Appellant failed to state a ground for the writ or to demonstrate probable cause for the issuance of the writ. View "Collier v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s motion requesting DNA testing pursuant to Ark. Code Ann. 16-112-201 et seq., which, under certain circumstances, permits postconviction testing of evidence.Appellant was convicted of first-degree murder. The Supreme Court affirmed on appeal. In this present action, Appellant requested DNA testing of a hair and other evidence, including the victim’s clothing and materials used to bind the victim’s body. In affirming the circuit court’s denial of relief, the Court held that Appellant’s requests for testing lacked merit. View "Martin v. State" on Justia Law

The Supreme Court affirmed in part and reversed and dismissed in part the order of the circuit court denying Appellant’s petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5.The Court reversed and dismissed as to the issue of whether trial counsel’s failure to present the affirmative defense of not guilty by reason of mental disease or defect was ineffective assistance of counsel, holding that the trial court did not have jurisdiction to consider this issue. The Court otherwise affirmed, holding (1) the trial court did not err in finding that counsel did not provide ineffective assistance as to Appellant’s remaining allegations of defective representation; and (2) the cumulative error rule in allegations of ineffective assistance of counsel should not be recognized in Arkansas. View "Lacy v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant’s petition requesting that the court reconsider and/or modify the sentence imposed in his criminal case, holding that the trial court did not err in finding that it did not have the authority to grant the relief requested by Appellant.In his petition, Appellant raised no issue of an illegal sentence. Because Appellant did not file his petition to modify the sentence until more than nineteen years after the mandate issued - well outside the statutory sixty-day period for the relief he sought - there was no clear error in the trial court’s denial of relief. View "Stewart v. State" 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, which rendered moot Petitioner’s pro se motion to rely to the State’s response to his coram nobis petition.In seeking coram nobis relief, Petitioner alleged that the prosecutor withheld material evidence and knowingly used perjured testimony, in violation of Brady v. Maryland, 373 U.S. 83 (1963). In denying relief, the Supreme Court held that Petitioner failed to allege sufficient grounds warranting coram-nobis relief and otherwise failed to demonstrate due diligence in bringing this petition. View "Lewis v. State" on Justia Law