Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant’s appeal from an order of the circuit court denying his pro se motion for relief from judgment filed pursuant to Ark. R. Civ. P. 60, thus rendering Appellant’s motions connected to the appeal moot.Appellant’s Rule 60 motion sought relief from an order of the circuit court denying his pro se petition for writ of habeas corpus, in which Appellant alleged that the judgment of conviction in his criminal case was illegal on its face. The Supreme Court held that neither Rule 60(b) nor Rule 60(c) are applicable as an avenue for relief from a judgment of conviction or from an order that denies a petition for writ of habeas corpus or other request for postconviction relief. View "Grant v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the trial court’s denial of his motion for a new trial based on newly discovered evidence, holding that it was clear from the record that Appellant could not prevail on appeal, thus rendering moot Appellant’s motion for extension of time to file the appellant’s brief.Appellant was found guilt of rape. Appellant later filed a motion for a new trial alleging that the victim recanted her trial testimony about where the rape had occurred. Appellant filed his motion for new trial based on newly discovered evidence more than six years after entry of his judgment of conviction. The Supreme Court dismissed the appeal, holding that Appellant’s motion for new trial was untimely. View "Riley v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of capital murder, kidnapping, and other crimes, holding that Defendant was not entitled to reversal of his convictions.Specifically, the Court held (1) the evidence was sufficient to support the convictions; (2) the trial court did not err in refusing to suppress three statements challenged by Defendant; (3) as to Defendant’s survey of twenty-six other adverse rulings made by the trial court, several of Defendant’s arguments were moot and others were not sufficiently argued; (4) the trial court’s evidentiary decisions were not erroneous; (5) there was no error in jury selection; and (6) Defendant’s remaining arguments were similarly unavailing. View "Tarver v. State" on Justia Law

The Supreme Court affirmed Appellant’s conviction of aggravated residential burglary and sentence of life imprisonment, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held that the circuit court (1) did not err in denying Appellant’s motion for directed verdict, (2) did not abuse its discretion in refusing to admit character and reputation evidence of a victim, (3) did not err in admitting text messages from Appellant’s cell phone, and (4) did not prejudicially err in refusing to allow Appellant to impeach the investigating officer with a prior inconsistent statement. View "Hill v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner neither demonstrated that the writ should issue nor was he diligent in raising his claims.Petitioner was convicted of capital murder and other crimes. Petitioner was serving a time of life imprisonment without parole on the capital-murder charge when he brought his petition, in which he asserted that his trial counsel provided ineffective assistance during trial. Because ineffective assistance of counsel claims are not grounds for the writ, Petitioner failed to demonstrate that the writ should issue. Further, Petitioner failed to give a valid excuse for his delay in raising the claim. View "Wooton v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the denial of his pro se second amended Ark. R. Crim. P. 37.1 petition, which rendered moot his motion for use of the record on appeal and for an extension of time to file his brief, holding that Appellant’s pro se second amended petition was untimely and successive.Appellant pleaded guilty to capital murder, terroristic threatening, and second-degree battery. Almost ten years later, Appellant filed his second amended petition. The trial court denied the petition, concluding that it had previously addressed and denied Appellant’s claims for postconviction relief. The Supreme Court affirmed because (1) Appellant’s original rule 37.1 petition was denied with prejudice, and the Supreme Court affirmed the denial on appeal; and (2) Appellant was not entitled to file a subsequent, untimely petition. View "Millsap 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.Petitioner’s claim for issuance of the writ was that he was incompetent to stand trial. The Supreme Court held that Petitioner did not establish a ground for the writ because (1) the sentencing court had before it at the time of Petitioner’s trial the issue of whether Petitioner was competent to stand trial; and (2) Petitioner failed to show that there existed some fact pertaining to the issue of insanity at the time of trial that would have prevented rendition of the judgment had it been known to the trial court and that was not brought forward before rendition of the judgment. View "Rayford v. State" on Justia Law

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