Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court dismissing Appellant’s petition for writ of habeas corpus on the grounds that Appellant failed to establish that the trial court lacked jurisdiction or that the commitment was invalid on its face.Appellant alleged in his petition that he was entitled to release from custody because the trial court in his case committed error in the conduct of the trial, the evidence was insufficient to support he judgment, and he was actually innocent. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s assertions of trial error and that he was innocent were not grounds for the writ. View "Stephenson v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s order denying his petition for writ of habeas corpus, which mooted the pro se motions Appellant filed in connection with the appeal, holding that Appellant could not prevail on appeal because he failed to allege a basis for the circuit court to grant the writ and demonstrated no clear error in the dismissal of his petition. In his petition, Appellant challenged a circuit court judgment reflecting his convictions, alleging that the judgment was facially invalid. The Supreme Court concluded that the type of claims raised by Appellant were not cognizable in a habeas proceeding. View "Tilson v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s order denying his petition for writ of habeas corpus, which mooted the pro se motions Appellant filed in connection with the appeal, holding that Appellant could not prevail on appeal because he failed to allege a basis for the circuit court to grant the writ and demonstrated no clear error in the dismissal of his petition. In his petition, Appellant challenged a circuit court judgment reflecting his convictions, alleging that the judgment was facially invalid. The Supreme Court concluded that the type of claims raised by Appellant were not cognizable in a habeas proceeding. View "Tilson v. Kelley" on Justia Law

The Supreme Court reversed the trial court’s denial of Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not provide sufficient written findings to demonstrate that Appellant was not entitled to relief on his ineffective assistance claims. The trial court denied relief without conducting an evidentiary hearing. The Court remanded to the trial court with directions to conduct a postconviction hearing limited to the two claims of ineffective assistance of counsel preserved by Appellant in this appeal. View "Collins v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his pro se petition for a writ of habeas corpus and for a writ of audita querela, which rendered moot his pro se motions related to the appeal. In the petition, Appellant argued that he was actually innocent and was entitled to habeas and audita querela relief based on Bailey v. United States, 516 U.S. 137 (1995). The circuit court denied the petition based on the lack of jurisdiction to hear either claim. The Supreme Court affirmed, holding that it was clear from a review of the record that the circuit court did not have jurisdiction to address the claims for postconviction relief under either of the two interchangeable remedies. View "Hill v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the denial of his petition filed under Ark. R. Crim. P. 37.1, which mooted Appellant’s motions in which he sought permission from the Supreme Court to include in the addendum of his brief a portion of the trial court’s docket listing.On remand from the Supreme Court, the trial court considered Appellant’s claims in the petition for Rule 37 relief. The court then denied and dismissed the petition. The Supreme Court affirmed, holding that the trial court correctly determined that Appellant was not entitled to relief on his allegations of trial error or ineffective assistance regarding those claims and that his direct challenge to the sufficiency of the evidence was not cognizable in this Rule 37 proceeding. View "McClinton v. State" on Justia Law

The Supreme Court treated Petitioner’s pro se motion for belated appeal and rule on clerk seeking to proceed with a belated appeal of the judgment convicting him of sexual assault in the second degree as a motion for belated appeal and remanded the matter to the trial court for an evidentiary hearing, holding that the proper disposition of the motion for belated appeal in this case will require findings of fact. Petitioner, who was convicted of sexual assault in the second degree, argued that his trial counsel failed to pursue an appeal on his behalf. Because the proper disposition of Petitioner’s motion for belated appeal will require findings of fact, the Supreme Court remanded this matter to the trial court for an evidentiary hearing. View "Beene v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s request to proceed in forma pauperis with a petition for a writ of habeas corpus, which mooted the motion before the Court in which Appellant sought an extension of time to file his brief.The habeas petition, Appellant sought to pursue as a pauper sought habeas relief based on new scientific evidence and alleged that his conviction should be dismissed because the trial court lacked jurisdiction. The circuit court denied the petition, finding that Appellant failed to allege facts that would support a colorable cause of action. The Supreme Court affirmed the denial of pauper status, holding that Appellant alleged no facts that would support issuance of the writ and failed to state a colorable cause of action. View "Muldrow v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, after a jury trial, of aggravated residential burglary, aggravated assault on a family or household member, and first-degree terroristic threatening and sentencing him as a habitual offender to life imprisonment plus fifteen years and a $10,000 fine. The Court held (1) the circuit court did not err by denying Defendant’s requests to represent himself at trial; and (2) the circuit court did not conduct a proper inquiry when denying Defendant’s motion for mistrial based on a juror looking up something with his cell phone and sharing that information with other jurors during guilt-innocence phase deliberations, but there was no reasonable probability of prejudice to Defendant in this case. View "Finch v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition for writ of habeas corpus, holding that the circuit court did not abuse its discretion in finding that Appellant stated insufficient grounds for the writ.In his writ, Appellant alleged that there was insufficient evidence to support the enhancements to the sentences for prior convictions noted on the judgment of conviction and that he was not competent when the crimes were committed or to stand trial. The circuit court found that Appellant’s petition failed to set forth a basis for the writ. The Supreme Court affirmed, holding (1) the circuit court’s application of Philyaw v. Kelley, 477 S.W.3d 503 (Ark. 2015), was not in error; and (2) the trial court did not abuse its discretion in finding that the grounds in Appellant’s petition did not support the writ. View "Ratliff v. Kelley" on Justia Law