Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Harmon v. State
The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition to correct an illegal sentence, holding that Petitioner failed to establish either that his sentence was illegal on its face or, at the time of sentence, that the sentencing court lacked subject-matter jurisdiction.Petitioner pleaded guilty to manslaughter and robbery and stipulated that he was a habitual offender. Petitioner was sentenced to sixty months in prison for manslaughter and 480 months for robbery, with his sentences to run consecutively. Petitioner later filed a petition for relief from an illegal sentence, which the circuit court denied. The Supreme Court affirmed, holding that Defendant's sentence fell within the maximum prescribed sentence and was legal on its face and that the circuit court did not clearly err in denying Petitioner's petition on all grounds. View "Harmon v. State" on Justia Law
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Criminal Law
Davis v. Payne
The Supreme Court granted Petitioner's pro se petition for a writ of mandamus directing Honorable Quincy Ross, circuit judge, to issue an order acting on Petitioner's habeas petition within thirty days of the date of this opinion, holding that Petitioner was entitled to the writ.Petitioner pleaded guilty to theft of property and was sentenced to sixty months' imprisonment as a habitual offender. In his mandamus petition, Petitioner asserted that Judge Ross had failed timely to act on his petition for writ of habeas corpus. The Supreme Court granted the writ because Petitioner's habeas petition had been pending since 2021, no action had been taken, and the State's response offered no explanation for the extended delay. View "Davis v. Payne" on Justia Law
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Criminal Law
Gonder v. State
The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to vacate and dismiss judgment and commitment order due to lack of jurisdiction filed under Ark. Code Ann. 16-90-111, holding that there was no error.In his motion, Appellant argued that the trial court lacked jurisdiction to convict him because he did not engage in the criminal conduct contemplated by Ark. Code Ann. 5-54-119 and because the elements of section 5-54-119 were not established. The Supreme Court affirmed the trial court's denial of the motion, holding that the trial court did not clearly err when it found that Appellant did not state a cause of action under section 16-90-111(a). View "Gonder v. State" on Justia Law
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Criminal Law
Mitchell v. State
The Supreme Court affirmed the judgment of the circuit court convicting and sentencing Defendant for first-degree battery and failure to appear on a felony, holding that the circuit court did not abuse its discretion by denying Defendant's motion to substitute counsel and that there was substantial evidence to support Defendant's conviction for first-degree battery.After a three-day trial, the jury convicted Defendant of first-degree battery and failure to appear but acquitted him of second-degree battery. The Supreme Court affirmed, holding (1) because Defendant was indigent he was not entitled to the counsel of his choice, and therefore, the circuit court did not abuse its discretion in denying Defendant's motion to substitute counsel; and (2) the State introduced substantial evidence sufficient to support Defendant's conviction for first-degree battery. View "Mitchell v. State" on Justia Law
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Criminal Law
Hogan v. Payne
The Supreme Court affirmed the denial of Appellant's petition for writ of habeas corpus arguing that his sentence was illegal and that an amendment to the information was to vague to suffice as an amendment, holding that Appellant was not entitled to relief.After a jury trial, Appellant was convicted of possession of cocaine with intent to deliver. The jury sentenced Appellant as a habitual offender to a total of 125 years' imprisonment, and the court of appeals affirmed. Appellant later filed this petition for a writ of habeas corpus arguing that the State's oral amendment to the information was deficient. The circuit court denied the petition. The Supreme Court affirmed, holding that the trial court had authority to sentence Appellant as a habitual offender, and his sentence was within the range authorized under Ark. Code Ann. 5-4-501(b). View "Hogan v. Payne" on Justia Law
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Criminal Law
Grady v. State
The Supreme Court affirmed Defendant's conviction of five counts of rape and his sentence to five concurrent terms of life imprisonment, holding that the circuit court did not abuse its discretion by denying Defendant's motion for a continuance.After a trial, Defendant was convicted of raping his minor stepson and sentenced to life imprisonment. On appeal, Defendant argued that the circuit court abused its discretion by denying a continuance to investigate a supplemental DNA report allegedly provided to the defense the Friday before trial. The Supreme Court rejected the argument and affirmed, holding that Defendant never requested a continuance to obtain an expert to perform DNA testing and that Defendant's argument was not preserved for appellate review. View "Grady v. State" on Justia Law
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Criminal Law
White v. State
The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of life imprisonment, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) as to four of Defendant's allegations of error on appeal, five of them were not preserved; (2) the trial court did not abuse its discretion by rejecting Defendant's proffered justification instructions; (3) the trial court did not prevent Defendant from testifying about the victim's past violent acts; (4) Defendant was not entitled to resentencing based on the standard sentencing range for a Class Y felony; and (5) the trial court did not abuse its discretion by admitting two challenged photographs. View "White v. State" on Justia Law
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Criminal Law
Chatmon v. Payne
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to demonstrate probable cause for issuance of the writ.Appellant was found guilty of three counts of aggravated robbery and one count of theft of property and sentenced to three life sentences. Appellant later filed a petition for writ of habeas corpus alleging that his convictions were invalid because the circuit judge who presided over his trial did not legally hold the position. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ. View "Chatmon v. Payne" on Justia Law
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Criminal Law
Hunter v. Payne
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for a writ of habeas corpus and denied his motion to amend his reply brief, holding that there was no error.Appellant filed a petition for a writ of habeas corpus alleging that his sentence exceeded the maximum authorized by Ark. Code Ann. 5-64-422 and that the statute of limitations had expired on the primary offense underlying his engaging in a continuing criminal enterprise conviction. The Supreme Court affirmed, holding (1) Appellant's sentence was well within the statutory limits and was not illegal; and (2) the criminal information was timely filed for statute of limitations purposes. View "Hunter v. Payne" on Justia Law
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Criminal Law
Lowery v. Payne
The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for a writ of habeas corpus filed in the county of his incarceration, holding that there were no grounds, stated in either the petition filed in the circuit court or in Appellant's arguments, on which a writ of habeas corpus could issue.On appeal, as he did below, Appellant argued that the trial court lacked jurisdiction to try and convict him by failing to adhere to Arkansas Supreme Court Administrative Order No. 5 and because he was not allowed to present certain evidence that would have exonerated him. The Supreme Court affirmed, holding there was no basis for finding that a writ of habeas corpus should issue. View "Lowery v. Payne" on Justia Law
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Criminal Law