Justia Arkansas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the circuit court’s order dismissing Appellant’s pro se petition for judicial review of an adjudication made by the Arkansas Parole Board pursuant to the Arkansas Administrative Procedure Act. In his petition, Appellant alleged that the Board unconstitutionally denied his transfer eligibility to the Department of Community Correction for one year in violation of Arkansas’s parole statutes and the Board’s own regulations. In affirming the dismissal of the petition, the Supreme Court held that Appellant failed to allege sufficient facts that would entitle him to review of the Board’s decision to deny transfer. View "Kennedy v. Arkansas Parole Board" on Justia Law

The Supreme Court denied Petitioner’s pro se motion seeking permission to proceed with a belated appeal of an order denying a motion for reconsideration of the denial of a postconviction motion that alleged multiple grounds for relief. After Petitioner was convicted of first-degree murder, he filed a pro se petition seeking postconviction relief under Ark. R. Crim. P. 37.1. In the same petition, Petitioner requested a writ of error coram nobis, a writ of habeas corpus, and other relief. The trial court denied the petition and denied Petitioner’s motion for reconsideration. Regarding the instant motion for belated appeal, the Supreme Court denied relief because Petitioner failed to establish good cause for his failure to file a timely notice of appeal. View "Griffis v. State" on Justia Law

Petitioner filed in the Supreme Court a pro se petition for writ of mandamus arguing that the circuit judge had not acted in a timely manner on a pro se petition for writ of error cream nobis filed in the circuit court. A different circuit judge filed a timely response to the mandamus petition, noting that Petitioner’s coram nobis petition had been ruled on and denied. The Supreme Court declared the mandamus petition moot because Petitioner received the relief he sought and the subject of the mandamus action had been acted on by the substituted circuit judge. View "Griffin v. Alexander" on Justia Law