Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed Appellant’s convictions of one count of rape and one count of sexual indecency with a child, for which Appellant was sentenced to concurrent terms of life and seventy-two months, respectively. On appeal, Appellant argued that the circuit court abused its discretion by admitting evidence that he performed similar sexual acts on two other young boys and on a physically disabled man. The Supreme Court disagreed, holding (1) the circuit court did not abuse its discretion in ruling that the testimony of the two other boys was admissible under the pedophile exception to Ark. R. Civ. P. 404(b); and (2) the circuit court abused its discretion in admitting the testimony of the physically disabled man under the pedophile exception but did not abuse its discretion in admitting the testimony as independent-relevance evidence under Rule 404(b). View "Hortenberry v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction for capital murder for which Defendant was sentenced to life imprisonment with the possibility of parole in twenty-eight years. On appeal, Defendant challenged the sufficiency of the evidence and the admission of certain hearsay testimony. The Supreme Court held (1) the circuit court did not err in permitting hearsay testimony of an emergency medical technician regarding a statement the victim had made to him while receiving medical treatment under a hearsay exception; and (2) the circuit court did not err in denying Defendant’s motion for directed verdict because the evidence was sufficient to sustain Defendant’s conviction for the murder of another person in the commission or attempted commission of a robbery. View "Hicks v. State" on Justia Law

The Supreme Court dismissed the State’s appeal from an order for the circuit court granting Defendant’s motion to suppress two statements he made, holding that the appeal was improper under the court’s rules. After the Supreme Court remanded the case for a new trial, the circuit court ruled that two of Defendant’s statements would be suppressed. On appeal, the State argued that the circuit court erred because it did not consider the totality of the circumstances and only considered Defendant’s mental incompetency when making its ruling. The Supreme Court held that this was not a proper State appeal because the State’s arguments were based on the application and not the interpretation of the court’s criminal rules. View "State v. Newman" on Justia Law

The Supreme Court affirmed the circuit court’s ruling that defense counsel was not ineffective for failing to dismiss the drug offense charges against Defendant based on a speedy-trial violation. The circuit court found that sufficient excludable time periods should be charged against Defendant such that no speedy-trial violation occurred. The Supreme Court agreed, holding that the circuit court did not err in finding that counsel’s failure to raise a speedy-trial argument was not deficient because there was no speedy-trial violation and that Defendant failed to meet the first prong of Strickland. View "Turner v. State" on Justia Law

The Supreme Court reversed the circuit court’s order dismissing misdemeanor negligent-homicide charges against Defendant due to the expiration of the one-year statute of limitations. Before the circuit court, Defendant argued that because the criminal information had not been filed until more than one year after the accident that led to the charges occurred, the applicable statute of limitations had expired. The circuit court granted the motion to dismiss. The Supreme Court reversed and remanded the case, holding that the circuit court erred in its interpretation of Ark. Code Ann. 5-1-109(f) and in concluding that the prosecution had not commenced within the applicable limitations period. View "State v. Ledwell" on Justia Law

The Supreme Court affirmed the order of the habeas court denying Petitioner’s petition for a writ of habeas corpus, holding that Petitioner did not state a ground on which a writ of habeas corpus could be issued.Petitioner, an inmate incarcerated for several crimes, argued in his habeas petition that he was subjected to double jeopardy because the same elements that were used to prove that he committed rape were used to prove that he committed attempted rape. Petitioner also argued that the judgment was invalid because attempted rape is a lesser-included offense of rape. The Supreme Court held that the circuit court was not clearly erroneous in denying habeas relief, as the claims Petitioner raised in his petition were not within the purview of a habeas proceeding. View "Edwards v. Kelley" on Justia Law

The Supreme Court affirmed the trial court’s conclusion that Appellant’s attempt to waive his right to counsel and represent himself at trial was equivocal and the court's decision to proceed with Appellant’s original counsel. After Appellant requested to waive his right to counsel and represent himself at trial, Appellant engaged in multiple instances of uncertainty while being told of the consequences of self-representation. Therefore, the trial court ruled that Appellant’s invocation was equivocal. The Supreme Court agreed, holding that Appellant’s attempt to waive counsel and self-represent was not sufficiently unequivocal. View "Reed v. State" on Justia Law

The Supreme Court granted a writ of mandamus to Petitioner, an inmate, to the extent it required Judge Edwin A. Keaton to rule on an outstanding pleading for postconviction relief but denied the request to direct Judge Keaton on how to rule on Petitioner’s claims. Petitioner was convicted of first-degree murder. Petitioner later filed a pleading seeking three separate avenues for postconviction relief. Judge Keaton did not rule on the claims. The Supreme Court granted Petitioner’s request for a ruling on his claims for postconvicton relief but denied the request to compel Judge Keaton to grant the relief sought in Petitioner’s pleading, as “a motion or case should [not] be delayed beyond a time reasonably necessary to dispose of it.” View "Hill v. Keaton" on Justia Law

The Supreme Court denied Petitioner’s request that that court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in his criminal case. Petitioner, who was found guilty of unlawful use of a communication device and delivery of a controlled substance, argued that the writ should issue in his case because the State suppressed exculpatory evidence at the time of his trial. The Supreme Court denied the petition, holding that Petitioner failed to establish that there was a reasonable probability that the judgment of conviction would not have been rendered, or would have been prevented, had the alleged exculpatory evidence been disclosed at trial. View "Grady v. State" on Justia Law

The Supreme Court affirmed the judgment of circuit court denying Petitioner’s second pro se petition for writ of error coram nobis. In the petition, Petitioner alleged that his guilty plea was obtained by coercion and intimidation and that the prosecution violated Brady v. Maryland, 373 U.S. 83 (1963), by withholding material evidence. The Supreme Court held that the trial court did not err in finding that Petitioner failed to demonstrate that a writ of error coram nobis should be issued because his guilty plea was appropriately entered and because Petitioner failed to meet his burden that there was a reasonably probability that the judgment of conviction would not have been rendered, or would have been prevented, had the information at issue been disclosed at trial. View "Smith v. State" on Justia Law