Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed in part the judgment of the circuit court convicting Defendant of two counts of rape and three counts of sexual assault in the second degree, holding that the circuit court erred by not conducting an in camera review of a Department of Human Services (DHS) file to determine if it contained information material to Defendant’s defense.Defendant was charged with sexual misconduct involving juveniles. Among other motions, Defendant filed a motion to compel production of a DHS file, which he argued contained a report of a sexual abuse allegation an alleged victim made against her biological father that was found to be unsubstantiated. The trial court denied the motion. After a trial, Defendant was convicted. The Supreme Court held (1) the circuit court properly denied Defendant’s motions for a directed verdict and for a new trial; (2) the circuit court erred by not allowing certain testimony, but the error was not prejudicial; and (3) the court erred by not conducting an in camera review of the DHS file. On remand, the circuit court must conduct an in camera review of the DHS file pursuant to the procedure set forth in Pennsylvania v. Ritchie, 480 U.S. 39 (1987), and if the file contains information that probably would have changed the outcome of the trial, Defendant should receive a new trial unless the nondisclosure was harmless beyond a reasonable doubt. View "Taffner v. State" on Justia Law

The Supreme Court affirmed Appellant’s conviction of capital murder, holding that there was substantial evidence to support the jury’s verdict that Appellant committed capital murder, and therefore, the circuit court did not err by denying Appellant’s motion for directed verdict.After a jury trial, Appellant was found guilty of the capital murder of Patricia Wellington. Appellant received a sentence of life imprisonment. The Supreme Court held that substantial evidence supported the jury’s finding that Appellant murdered Patricia, and substantial evidence supported the jury’s determination that Appellant acted with premeditation and deliberation. View "Hyatt v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court’s denial of Appellant’s petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37. Appellant, who was convicted of first-degree murder and possession of a firearm, argued in his petition that he received ineffective assistance of counsel due to counsel’s failure to present certain jury instructions. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court held (1) the circuit court did not err in denying Appellant’s claim that trial counsel was ineffective in failing to present the proper jury instruction on justification; but (2) because the circuit court failed to make written findings in accordance with rule 37.3(a) in regards to Appellant’s claim that trial counsel was ineffective in failing to present the proper jury instruction on extreme-emotional-disturbance manslaughter, the case must be remanded for the court to make such findings. View "Douglas v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion for belated appeal of an order that dismissed Petitioner’s pro se petition for declaratory judgment and mandamus relief, holding that the order that Petitioner would appeal was not a final, appealable order.In his petition, Petitioner alleged that Defendants, including the director of the Arkansas Department of Correction (ADC), violated his due process rights and implemented disciplinary procedures against him in violation of ADC policy. The circuit court dismissed the petition without prejudice, finding that Petitioner had failed to serve the defendants as required. The Supreme Court denied Petitioner’s motion for belated appeal of the order, holding that the order was not a final, appealable order because Petitioner was allowed under the procedural rules to refile his claim after his petition had been dismissed. View "McCullough v. Kelley" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s pro se petition and amended petition to correct an illegal sentence. The trial court ruled that Appellant was not entitled to relief under Ark. Code Ann. 16-90-111 because he did not establish that his sentences were illegal on their face. The court further held that, to the extent Appellant raised claims pursuant to Ark. R. Crim. P. 37.1, his claims were untimely and successive. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief to correct an illegal sentence because his sentence was illegal on its face; and (2) to the extent Appellant raised claims regarding the illegal imposition of sentence or of ineffective assistance of counsel, those claims should have been raised in a timely Rule 37.1 petition. View "Swift v. State" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s petition to correct an illegal sentence, holding that Appellant’s petition failed to state a basis for relief under either Ark. Code Ann. 16-90-111 or Ark. R. Crim. P. 37.1.Appellant was convicted of aggravated robbery and sentenced as a habitual offender to seventy-five years’ imprisonment. The Supreme Court affirmed. Almost twenty-five years after the mandate issued Appellant filed this petition alleging that his sentence was illegal. The trial court found that the petition was untimely and successive. The Supreme Court affirmed, holding that the only timely challenge before the circuit court was Defendant’s facial challenge to his sentence, and the court did not err in denying relief. View "White v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion filed pursuant to the state Freedom of Information Act, in which Petitioner sought a copy at public expense of certain written material on file with the Supreme Court. Specifically, Petitioner asked for copies of four coram nobis petitions that he filed in his criminal case but sought to be excused from paying the standard photocopying fee charged by the clerk’s office. In denying the petition, the Supreme Court held that Petitioner failed to show that copies of the coram nobis petitions should be provided to him at no cost. View "Scott v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion filed pursuant to the state Freedom of Information Act, in which Petitioner sought a copy at public expense of certain written material on file with the Supreme Court. Specifically, Petitioner asked for copies of four coram nobis petitions that he filed in his criminal case but sought to be excused from paying the standard photocopying fee charged by the clerk’s office. In denying the petition, the Supreme Court held that Petitioner failed to show that copies of the coram nobis petitions should be provided to him at no cost. View "Scott v. State" on Justia Law

The Supreme Court dismissed this appeal from the circuit court’s denial of Appellant’s pro se petition for a writ of error coram nobis, in which Appellant alleged entitlement to coram nobis relief primarily on the basis of allegations of ineffective assistance of counsel. The Supreme Court dismissed Appellant’s appeal, which mooted his motion for an extension of time to file his appellate brief, holding that Appellant’s allegations were not cognizable in coram nobis proceedings, and therefore, Appellant could not prevail on appeal. View "Gray v. State" on Justia Law

The Supreme Court dismissed this appeal from the circuit court’s denial of Appellant’s pro se petition for a writ of error coram nobis, in which Appellant alleged entitlement to coram nobis relief primarily on the basis of allegations of ineffective assistance of counsel. The Supreme Court dismissed Appellant’s appeal, which mooted his motion for an extension of time to file his appellate brief, holding that Appellant’s allegations were not cognizable in coram nobis proceedings, and therefore, Appellant could not prevail on appeal. View "Gray v. State" on Justia Law