Justia Arkansas Supreme Court Opinion Summaries

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

The Supreme Court dismissed Appellant’s appeal from the trial court’s denial of his pro se petition for writ of habeas corpus filed under Act 1780 of 2001 Acts of Arkansas, Ark. Coe Ann. 16-112-201 to -208, which rendered moot Appellant’s pro se motion for leave to add to the addendum of his appeal brief. The court ruled that it need not consider Appellant’s motion to supplement the addendum because there was clearly no merit to his appeal. Specifically, the court held that Appellant failed to demonstrate entitlement to habeas relief under Act 1780. View "McClinton v. State" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s pro se petition and amended petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, in which Appellant raised multiple claims of ineffective assistance of counsel. The trial court conducted an evidentiary hearing and issued written findings on those issues it considered to have been raised during the course of the hearing. At that hearing, Appellant did not specifically reassert all the claims set forth in the petitions. On appeal, Appellant claimed that the trial court committed reversible error pursuant to Ark. R. Crim. P. 37.3(a) by failing to specifically all the claims raised in his petitions. The Supreme Court affirmed, holding (1) Appellant waived any issues he alleged should have been ruled on by the trial court; and (2) because Appellant failed to argue the merits of the claims on which the trial court ruled, those issues were considered abandoned. View "Brown v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from an order of the Lee County Circuit Court denying his pro se petition for writ of habeas corpus filed under Ark. Coe Ann. 16-112-101 to -123. In his petition, Appellant argued that the writ should issue because the judgment entered in his case was illegal where the trial court ordered a firearm enhancement to be served consecutively to the sentence imposed for first-degree murder. The Supreme Court dismissed the appeal because Appellant was no longer incarcerated within the jurisdiction of the Lee County Circuit Court. View "Noble v. State" on Justia Law