Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Gonder v. Kelley
The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se motions seeking reconsideration of Appellant’s petition for writ of habeas corpus that had previously been dismissed by the circuit court. Pending the Supreme Court’s review, Appellant additionally filed motions to have counsel appointed and for judicial notice of adjudicative facts in the court. The Supreme Court declared Appellant’s motions filed in this appeal moot when it dismissed Appellant’s appeal, holding that Appellant failed to demonstrate that the circuit court was required to grant reconsideration of his habeas petition. View "Gonder v. Kelley" on Justia Law
Posted in:
Criminal Law
Gardner v. State
The Supreme Court affirmed the trial court’s denial of Appellant’s pro se petition filed pursuant to Ark. Code Ann. 16-90-111 to correct a sentence imposed on him in 2004 on the grounds that the sentence was illegal. The trial court denied relief because the petition was not timely filed under Ark. R. Crim. P. 37.2. The Supreme Court dismissed the appeal, albeit for different reasons, holding (1) the trial court had authority to grant relief under the statute if the sentence imposed on Appellant had indeed been illegal; and (2) Appellant’s sentence was legal, and Appellant’s additional claims were not timely raised. View "Gardner v. State" on Justia Law
Posted in:
Criminal Law
Chatmon v. State
The Supreme Court denied Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in his criminal case, an amendment to the petition, and Petitioner’s motion for leave to file a response to the State’s response to the petition. In his petition, Petitioner contended that, at trial, the State violated the provisions of Brady v. Maryland, 373 U.S. 83 (1963) by presenting false testimony from a certain witness and that the State failed to provide information to the defense concerning the witness’s criminal history, arrest records and rap sheet. The Supreme Court held that Petitioner failed to state a ground for the writ and thus denied the coram nobis petition. View "Chatmon v. State" on Justia Law
Posted in:
Criminal Law
Brown v. State
The Supreme Court dismissed Appellant’s appeal from a decision of the trial court that denied Appellant’s pro se petition for declaratory relief. In his petition, Appellant asked the trial court to enforce the terms of an alleged verbal plea agreement concerning his parole eligibility. Because Appellant did not join the director of the Arkansas Department of Correction (ADC) as a party to this action, there was no justiciable controversy as to the rights and obligations of the ADC under this action, and for the same reasons, Appellant’s allegation that the ADC violated his right to due process was not justiciable under the declaratory-judgment statute. View "Brown v. State" on Justia Law
Posted in:
Criminal Law
Bell v. State
The Supreme Court affirmed the denial of Appellant’s pro se petition filed under Ark. Code Ann. 16-90-111. In his petition, Appellant argued (1) the two sentences of life imprisonment that were imposed on him in 1994 were facially illegal under the Eighth Amendment because the State did not prove in the sentencing proceeding that he was incorrigible and irreparably corrupt; and (2) his sentences were cruel and unusual and violated the Eighth Amendment. The Supreme Court held that the grounds for relief raised in Appellant’s petition were of the type that should have been raised in the trial court. View "Bell v. State" on Justia Law
Posted in:
Criminal Law
Ashby v. State
The Supreme Court affirmed the circuit court’s denial of Appellant’s in forma pauperis petition. Appellant filed the petition so that he might initiate an action seeking “writs of prohibitory petitions” challenging a risk assessment made under the Sex Offender Registration Act. The circuit court ultimately denied Appellant’s petition to proceed in forma pauperis. The Supreme Court affirmed on the grounds that Appellant failed to state a colorable cause of action warranting the issuance of a writ of prohibition because it failed to present a justiciable issue as a matter of law. View "Ashby v. State" on Justia Law
Posted in:
Criminal Law
Harmon v. State
Appellant, an inmate of the Arkansas Department of Correction (ADC), was part of a class-action lawsuit brought against the City of Helena-West Helena and Phillips County. The lawsuit settled, and the ADC received a settlement check that was deposited into Appellant’s inmate trust-fund account. Appellant then initiated a series of unsuccessful grievances alleging that ADC had confiscated the funds without his permission by depositing the check into his inmate account and that the ADC had improperly refused his withdrawal request to pay legal fees. The State later filed a petition for reimbursement of costs of care and a motion for leave to deposit Appellant’s funds with the court. The circuit court granted the State’s petition and directed that the settlement funds be deposited into the State treasury. The Supreme Court remanded to the circuit court for an evidentiary hearing, holding that the circuit court failed to make findings mandated by statutory authority. View "Harmon v. State" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Ward v. State
By per curiam opinion, the Supreme Court denied Appellant’s pro se petition for a writ of error coram nobis. In this same opinion, however, the court held that Appellant’s sentence was illegal and remanded the case to the circuit court for resentencing. The circuit court “reimposed” the same sentence on remand that the Supreme Court had held was illegal. Specifically, the court asserted that “the supreme court, with all their power, cannot change the statute.” The Supreme Court reversed, holding that the circuit court erred and exceeded its jurisdiction in looking beyond the Supreme Court’s opinion in Ward I and improperly attempted to correct any perceived error. View "Ward v. State" on Justia Law
Posted in:
Criminal Law
Wilson v. State
The Supreme Court affirmed Appellant's convictions for one count of aggravated robbery, two counts of robbery, three counts of theft of property, and one count of commercial burglary, holding (1) the circuit court did not err in denying Appellant’s motions for a directed verdict on the aggravated robbery and robbery counts, as substantial evidence supported the three convictions; and (2) a conviction imposed on a juvenile sentenced as an adult may be used as the basis for an increased penalty imposed under the habitual offender statute, and therefore, the circuit court did not err in sentencing Appellant to life imprisonment for aggravated robbery. View "Wilson v. State" on Justia Law
Posted in:
Criminal Law
Lewis v. State
Appellant appealed his convictions of capital murder and kidnapping, arguing that the circuit court erred in denying his motions to suppress on five separate grounds. The State cross-appealed, arguing that the circuit court erred in granting Appellant’s motion to suppress evidence seized pursuant to two search warrants. The Supreme Court affirmed the denial of Appellant’s motions to suppress and dismissed the State's cross-appeal, holding (1) with regard to some of Appellant’s motions to suppress, the circuit court did not err in denying the motions, and with regarding to the remaining motions the court was precluded from addressing Appellant’s arguments; and (2) the State’s cross-appeal was untimely. View "Lewis v. State" on Justia Law
Posted in:
Criminal Law