Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Burns v. State
The Supreme Court dismissed Appellant’s appeal from a pre-plea denial of a motion for continuance. Appellant, who was represented by a public defender, was sentenced to life in prison following a plea of guilty to plea. Before the plea agreement proceedings began, Appellant requested a continuance so that he could hire private counsel. The circuit court denied the request. Appellant’s sole argument on appeal was that the circuit court wrongly denied him his constitutional right to choice of counsel when it denied his continuance. The Supreme Court dismissed this appeal for lack of jurisdiction because the appeal did not fall within the limited circumstances under which the court may hear appeals following guilty pleas. View "Burns v. State" on Justia Law
Posted in:
Criminal Law
Cage v. State
The Supreme Court affirmed Appellant’s convictions for capital murder and first-degree murder. The jury sentenced to Appellant life imprisonment without parole for capital murder and life imprisonment for first-degree murder. Contrary to Appellant’s arguments on appeal, the Supreme Court held (1) the circuit court did not err in determining that Appellant was competent to stand trial; and (2) the circuit court did not err in refusing to instruct the jury as to Appellant’s mental state at the time of the offense. Further, in accordance with Arkansas Supreme Court Rule 4-3(i), the court examined the record of all objections, motions, and requests that were decided adversely to Cage, and no prejudicial error was found. View "Cage v. State" on Justia Law
Posted in:
Criminal Law
Woods v. State
The Supreme Court affirmed Defendant’s convictions for the kidnapping and murder of his girlfriend. A jury sentenced Defendant to life imprisonment without the possibility of parole for murder plus forty years imprisonment for kidnapping. In affirming the convictions on appeal, the Supreme Court held that the trial court did not err in denying Defendant’s challenges to the State’s use of three peremptory strikes against black potential jurors during jury selection because the State provided sufficient race-neutral explanations to justify its use of the peremptory strikes. View "Woods v. State" on Justia Law
Rogers v. Knight
The Supreme Court affirmed the circuit court’s dismissal of Appellant’s petition for declaratory judgment and writ of mandamus pertaining to the statutes that governed his parole-eligibility dates. Specifically, Appellant claimed he was parole eligible and had a right to a parole hearing. The circuit court dismissed the petition with prejudice, concluding that no justiciable controversy existed because Appellant was parole eligible and had a parole hearing. The Supreme Court held that the circuit court did not err in denying Appellant’s petition for declaratory judgment and writ of mandamus on the grounds that no justiciable controversy exists. View "Rogers v. Knight" on Justia Law
Posted in:
Criminal Law
Jones v. State
The Supreme Court affirmed the sentence Defendant received in connection with his guilty plea to rape and attempted murder. A jury sentenced Defendant to a term of life imprisonment for rape plus sixty years on the charge of attempted first-degree murder. The circuit court ordered the sentences to be served consecutively. Defendant requested the maximum sentence in open court. Defendant, however, appealed, challenging his sentence. The Supreme Court affirmed Defendant’s sentence and granted appellate counsel’s motion to withdraw, holding that certain adverse rulings challenged by Defendant did not provide meritorious grounds for reversal, and therefore, an appeal would be wholly frivolous. View "Jones v. State" on Justia Law
Posted in:
Criminal Law
Holloway v. State
The Supreme Court affirmed the circuit court’s order denying Appellant’s petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37. In 2014, Appellant pleaded guilty to murder in the first degree and to tampering with physical evidence. The circuit court sentenced Appellant to 420 months’ imprisonment for his first-degree murder charge, to be served concurrently with a 72-month term for his tampering-with-physical-evidence charge. Thereafter, Appellant filed a petition for postconviction relief, arguing that his counsel provided ineffective assistance. The circuit court denied the petition after an evidentiary hearing. Appellant later filed a motion for rule on clerk. The Supreme Court granted the motion and limited its review to the denial of Appellant’s petition for postconviction relief. The Supreme Court affirmed, holding that Appellant abandoned his Rule 37 claims on appeal. View "Holloway v. State" on Justia Law
Posted in:
Criminal Law
Pokatilov v. State
The Supreme Court affirmed Appellant’s conviction for possession of a controlled substance with purpose to deliver, for which Appellant was sentenced to five years’ probation and ordered to pay a $5000 fine. The court held (1) the trial court did not err by denying Appellant’s motions for directed verdict; (2) the trial court did not err by failing to give Appellant’s proffered jury instruction regarding constructive possession; and (3) the trial court did not commit clear error in denying Appellant’s motion to suppress evidence seized as a result of a search. View "Pokatilov v. State" on Justia Law
Hortenberry v. State
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
Posted in:
Criminal Law
Hicks v. State
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
Posted in:
Criminal Law
State v. Newman
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
Posted in:
Civil Rights, Criminal Law