Justia Arkansas Supreme Court Opinion Summaries

Petitioner filed in the Supreme Court a pro se petition to reinvest jurisdiction in the trial court to consider a second petition for writ of error coram nobis. Petitioner was convicted of capital murder and aggravated robbery. As grounds for the petition, Petitioner alleged that the prosecution committed misconduct in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) although Petitioner attempted to frame each of his claims as a Brady violation, most were simply allegations of trial error, which are not cognizable in coram nobis proceedings; and (2) Petitioner failed to demonstrate a Brady violation on any of his claims. View "Travis v. State" on Justia Law

Appellant, who was convicted of second-degree sexual assault and sexual indecency with a child, filed in the trial court a request for an amended sentencing order based on a pro se motion for jail-time credit, alleging that he was entitled to 547 days’ credit for his pretrial detention. The trial court entered an amended order, but the order did not set forth the number of jail-time days to which Appellant was entitled. Appellant appealed. The trial court subsequently granted the State’s motion to supplement the record and entered a second amended order, which specifically added 556 days for jail-time credit. The Supreme Court dismissed Appellant’s appeal, holding that the second amended order rendered the appeal moot. View "Matlock v. State" on Justia Law

Appellant appealed the trial court’s denial of his petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-11b and petition for writ of habeas corpus seeking release from custody. The Supreme Court affirmed, holding (1) the trial court correctly found that the habeas petition was not properly addressed to the trial court, therefore depriving the trial court of jurisdiction; and (2) the trial court did not err in denying relief under section 16-90-11 because Appellant’s allegations of ineffective assistance of counsel and sufficiency of the evidence and his assertion of constitutional error did not implicate the facial validity of the judgment and were not within the purview of section 16-90-111. View "Leach v. State" on Justia Law

The Arkansas Supreme Court denied Petitioner’s pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Petitioner, who was convicted by a jury of capital felony murder and sentenced to life imprisonment without the possibility of parole, asserted in his petition that the prosecution committed a violation of Brady v. Maryland by withholding evidence at the time of trial. The Supreme Court held (1) the allegations advanced by Petitioner did not warrant reinvesting jurisdiction in the trial court to consider a coram nobis petition; and (2) further, Petitioner failed to exercise due diligence in bringing this coram nobis petition. View "Heffernan v. State" on Justia Law

Appellant appealed the circuit court’s order denying his petition for postconviction relief alleging ineffective assistance of counsel under Ark. R. Crim. P. 37.1. Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed the denial of postconviction relief, holding that the circuit court did not clearly err in denying Appellant’s petition because any errors demonstrated by Appellant were either nonprejudicial under the test set forth in Strickland v. Washington or inappropriate for postconviction consideration. View "Russell v. State" on Justia Law

The Supreme Court dismissed the appeal of an order denying Appellant’s pro se petition for writ of habeas corpus, holding that Appellant failed to establish probable cause for issuance of the writ and, in any event, failed to state a cognizable claim for habeas relief. Appellant, who was convicted of first-degree murder and other crimes in three separate cases, alleged in his petition that his sentences were facially invalid and that he was actually innocent for the crimes for which he had been convicted, among other claims. The Court held that the circuit court’s order denying habeas relief was not clearly erroneous. View "Pennington v. Kelley" on Justia Law

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 the case and declared as moot Petitioners motions for, inter alia, appointment of counsel and to proceed forma pauperis. Petitioner, who was found guilty by a jury of first-degree murder, contended as grounds for issuance of the writ that he was denied effective assistance of counsel at his trial and on direct appeal, that he was actually innocent of the offense of which he was convicted, that the trial court made errors in his trial, and that the evidence was insufficient to sustain the judgment. The Court held (1) several of Petitioner’s claims were not a ground for the writ or not cognizable in a coram nobis proceeding; (2) as to the remaining claims, the allegations advanced by Petitioner did not warrant reinvesting jurisdiction in the trial court to consider a coram nobis petition; and (3) Petitioner failed to show that he exercised due diligence in raising his claims for coram nobis relief. View "Mitchell v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and employing a firearm as a means of committing the murder. Appellant was sentenced to life imprisonment for the murder conviction. On appeal, Appellant argued that the circuit court abused its discretion by allowing the State to introduce character evidence to show that he acted in conformity with his character when he committed the crimes. In response, the State asserted that because Appellant injected into the trial his character as a peaceful person, the State was allowed to rebut the evidence through cross-examination on relevant specific instances of Appellant’s conduct. The Supreme Court reversed Appellant’s convictions, holding that the circuit court abused its discretion in allowing the State to present testimony regarding Appellant’s character for lack of peacefulness because there was no testimony on that characteristic for the State to rebut. View "Stanton v. State" on Justia Law

After a retrial, Appellant was convicted of four counts of rape. Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, propounding three claims of ineffective assistance of counsel that allegedly occurred at his second trial. The circuit court denied the petition without a hearing. The Supreme Court remanded for a hearing on Appellant’s last two claims. On remand, after a hearing, the circuit court denied Defendant’s petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it concluded (1) that counsel’s decision to call no character witnesses during the trial was based on reasonable professional judgment, and (2) that counsel’s advice that Appellant not testify was based on reasonable professional judgment. View "Sandrelli v. State" on Justia Law

Attorney Jimmy Morris was the defense attorney of a defendant charged with first degree murder. The circuit court found Morris in contempt for failing to appear on time for the defendant’s jury trial and fined him $4,000. The Supreme Court affirmed, holding (1) the trial court did not err by finding Morris in criminal attempt because the court had substantial evidence with which to conclude that Morris’s behavior constituted a willful violation of the trial court’s scheduling order; and (2) under the particular facts of this case, the purpose of the contempt punishment will be accomplished by the lesser fine of $2,000. View "Morris v. State" on Justia Law