Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his motion to refile a habeas petition, holding that Appellant’s appeal was not from an appealable order and that it was clear from the record that he could not prevail on appeal.Appellant filed a pro se petition for writ of habeas corpus, which the circuit court dismissed. Thereafter, Appellant filed a motion to refile a habeas petition, which the circuit court denied. Appellant appealed. The Supreme Court dismissed the appeal, which rendered moot the motions filed in connection with the appeal, holding that the circuit court’s denial of Appellant’s motion was not a final judgment, and therefore, there was no final, appealable order entered in this case. View "Fields v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s pro se sixth petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In his petition, Petitioner argued that his rights under Miranda v. Arizona, 384 U.S. 436 (1966), were violated, that the bench-arrest warrant was invalid because it was not signed by a judge, and that trial counsel was ineffective. The Supreme Court denied the petition, holding (1) regarding the Miranda issue, Petitioner failed to demonstrate that the writ should issue because he failed to establish an error of fact extrinsic to the record that could not have been raised in the trial court; (2) Petitioner’s bench-arrest warrant argument violated the abuse-of-the-writ doctrine; and (3) Petitioner’s ineffective assistance of counsel claim was not grounds for the writ. View "Smith v. State" on Justia Law

The Supreme Court affirmed the trial court’s dismissal of Appellant’s pro se petition for writ of error coram nobis without a hearing. In the petition, Appellant claimed that he was coerced by trial counsel into pleading guilty to first-degree murder and aggravated assault and that the State’s evidence against him was insufficient to support the charges. The trial court concluded that Appellant failed to support his claim of coercion with a factual basis and that the petition was without merit. The Supreme Court affirmed, holding (1) Appellant’s allegations in the form of misrepresentations by counsel was the type of claim that should have been raised under Ark. R. Crim. P. 37 and not in coram nobis proceedings; and (2) Appellant’s final claim did not establish a ground for the writ. View "Ramirez v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant’s petition for writ of habeas corpus, in which Appellant argued that he should be reentenced because his sentence of life imprisonment imposed for an offense committed when he was a juvenile violated the Eighth Amendment pursuant to Miller v. Alabama, 467 U.S. 460 (2012).Appellant pleaded guilty to first-degree murder and other crimes stemming from offenses Appellant committed when he was fifteen years old. Appellant was sentenced to life imprisonment. The Supreme Court affirmed the circuit court’s denial of Appellant’s habeas petition, holding that because a recent statutory amendment by the Arkansas General Assembly created the possibility of parole for Appellant, Appellant’s sentence did not violate the requirements of Miller. View "Lohbauer v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of aggravated burglary. On appeal, Appellant argued that the circuit court erroneously denied his motion for a directed verdict because the State did not prove that he entered or remained in another person’s residence with the specific intent to commit a criminal offense and that he entered or remained in another person’s residence while armed with a deadly weapon. The Supreme Court disagreed, holding that the evidence was sufficient to support the conviction, and therefore, the circuit court did not err in denying appellant’s motion for directed verdict. View "Marshall v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal of the trial court’s denial of his pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, in which Appellant alleged grounds of prosecutorial misconduct, trial court error, and ineffective assistance of counsel. The dismissal of the appeal rendered moot the motion Appellant filed for extension of time to file his brief. The Supreme Court held (1) to the extent Appellant attempted to raise a claim of prosecutorial misconduct, it was not cognizable; (2) Appellant’s allegation of trial court error was not the basis for Rule 37.1 relief; and (3) Appellant’s allegations of deficient performance by trial counsel did not support an ineffective assistance of counsel claim. View "Ortega v. State" on Justia Law

The Supreme Court dismissed the appeal brought by the State challenging the circuit court’s grant of Defendant’s motion to dismiss first-degree-murder charges against him on the basis that the speedy-trial rules as stated in the Arkansas Rules of Criminal Procedure had not been followed. On appeal, the State argued, among other things, that the circuit court’s “mechanical” application of Ark. R. Crim. P. 28.1 and 30.1 in resolving the speedy-trial issue did not comport with the more flexible approach recognized by the United States Supreme Court in Barker v. Wingo, 407 U.S. 514 (1972). The Supreme Court held that this was not a proper State appeal because, while purporting to raise purely an issue of law, the legal issue could not be separated by the unique facts of the case. View "State v. Owens" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant’s pro se petition to correct and illegal sentence and denied Appellant’s motion for appointment of counsel. Appellant pleaded guilty to conspiracy to commit residential burglary and theft of property. Appellant received sentences of 240 months for each offense - 108 months’ imprisonment, with 132 months of the terms suspended. The Supreme Court held that the circuit court clearly erred when it denied Appellant’s petition to correct his illegal sentence because (1) Appellant’s sentence as a habitual offender for the Class D felony of theft of property exceeded the statutory maximum; and (2) regarding the Class C felony of conspiracy to commit residential burglary, unless Appellant was sentenced as a habitual offender, which the sentencing order failed to indicate, his sentence exceeded the statutory maximum of 120 months’ imprisonment. View "Green v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Appellant’s pro se motion for leave to file an amended declaratory judgment and petition to correct an illegal sentence, which rendered moot Appellant’s pro se motion for appointment of counsel filed in connection with this appeal. In his declaratory judgment action, Appellant sought a declaration that the lemons of a terrorist act as set forth in Ark. Code Ann. 5-13-310 are internally inconsistent, rendering the statute unconstitutional. In his petition to correct an illegal sentence, Appellant argued that his sentence was imposed pursuant to an allegedly unconstitutional statute. In affirming the denial of Appellant’s filings, holding (1) Appellant failed to establish that the challenged statute was unconstitutional; and (2) Appellant failed to demonstrate that his sentences were facially illegal. View "Anderson 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, in which Appellant argued that he was entitled to issuance of the writ because the judgment in his criminal case was illegal, that the sentencing order reflected only one of his convictions, that that authorities illegally seized his property, and that his arrest was illegal. The Supreme Court held that the circuit court properly denied Appellant’s habeas petition because the grounds raised by Appellant did not constitute a basis for a writ of habeas corpus. View "Story v. State" on Justia Law