Justia Arkansas Supreme Court Opinion Summaries

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

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