Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of residential burglary and sentenced to probation. Thereafter, Appellant was convicted of residential burglary and sentenced to a suspended imposition of sentence. Appellant was then convicted of aggravated robbery with a firearm enhancement. The trial court revoked the probation and suspended imposition of sentence and sentenced Appellant to life imprisonment and additional terms of imprisonment on each revocation. The Supreme Court affirmed the revocations but reversed and remanded as to the aggravated-robbery conviction and the firearm enhancement, holding (1) the trial court erred in denying Appellant’s motion to suppress his statement to a detective, and the error was not harmless; and (2) Appellant raised no allegation of error as to the revocations, and thus they stand. View "Coleman v. State" on Justia Law

Appellant pleaded guilty to murder in the first degree and was sentenced to 480 months in prison. Appellant later filed a petition for writ of habeas corpus seeking release from custody. The circuit court dismissed the petition because Appellant did not state a basis for issuance of the writ. Appellant appealed. The State filed a motion to dismiss the appeal on the grounds that Appellant had failed to submit a brief or otherwise take any action to pursue the appeal. The Supreme Court granted the motion, holding that the circuit court did not err in dismissing Appellant’s habeas petition because Appellant did not establish that the trial court lacked jurisdiction in his case or that the commitment was invalid on its face. View "Barber v. Kelley" on Justia Law

In 2006, Appellant pleaded guilty to first-degree battery and other offenses. In 2016, Appellant filed a second amended petition seeking coram nobis relief. The trial court denied relief, noting that it had found Appellant’s first coram nobis petition untimely and that the second petition “would be no timelier than the first.” On appeal, Appellant argued that he had a valid excuse for his delay because he did not become aware of an exculpatory statement allegedly withheld by the State until the time immediately before he filed his first petition for coram nobis relief. The Supreme Court reversed, holding (1) the trial court erred in limiting its examination of the due diligence requirement to the length of time from Appellant’s imposition of sentence without giving due consideration to Appellant’s claims regarding when he became aware of the allegedly exculpatory statement; and (2) Appellant stated sufficient allegations that may satisfy the due diligence requirement, and factual determinations were essential in deciding whether the writ should be granted. View "Scott v. State" on Justia Law

In 2014, Appellant, who was not a naturalized citizen of the United States, entered a negotiated change of plea to possession with the purpose to deliver methamphetamine. The circuit court accepted the plea and sentenced Appellant to two years and an additional term of three years’ suspended imposition of sentence (SIS). In 2015, Appellant filed a petition for writ of habeas corpus alleging that he was not provided with warnings regarding immigration and deportation pursuant to Padilla v. Kentucky, 559 U.S. 356 (2010). The circuit court denied the petition. The Supreme Court affirmed, holding that the court lacked jurisdiction to grant habeas relief because, despite Appellant’s SIS sentence, Appellant was not in custody as defined by this state’s laws. View "Rangel v. State" on Justia Law

Petitioner, who was convicted on charges of kidnapping, rape, and murder, filed a pro se petition for scientific testing under Act 1780 of 2001 Acts of Arkansas. Petitioner filed a petition for leave to proceed in forma pauperis on the Act 1780 petition on the same date. The circuit court denied the Act 1780 habeas petition and found that the in forma pauperis petition was denied “due to venue issues.” Petitioner filed a notice of appeal. The clerk, however, declined to file the record on the basis that it was not tendered within ninety days of the notice of appeal. Petitioner then filed a pro se motion for belated appeal in the Supreme Court. The court treated Petitioner’s motion as one for rule on clerk and denied the motion, holding that Petitioner could not prevail on appeal because he failed to state a basis on which the trial court could have ordered scientific testing under the statutes. View "Marshall v. State" on Justia Law

Appellant, who was incarcerated at a unit of the Arkansas Department of Correction located in Lee County for committing the crime of rape, filed a pro se petition for writ of habeas corpus in the Lincoln County Circuit Court. The circuit court dismissed the petition. Appellant sought to appeal. Now before the court was Appellant’s motion for extension of time to file brief. The Supreme Court dismissed Appellant’s appeal, holding that Lincoln County Circuit Court was without jurisdiction to dictate Appellant’s release because Appellant was not currently in that county. The dismissal of the appeal rendered the motion moot. View "Williams v. Kelley" on Justia Law

Appellant, who was convicted of rape, filed a pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111. The trial court denied the petition. Appellant appealed. The Supreme Court found good cause to reverse without considering Appellant’s arguments concerning the merits of his petition for relief under the statute. The court held that because the judge who ruled on Appellant’s section 16-90-111 petition was, in fact, the prosecuting attorney at his trial for rape, a serious appearance impropriety was created because the judge did not refrain from presiding over a case in which he might be interested. The court remanded the matter so that a different circuit judge can rule on the petition. View "Latham v. Kelley" on Justia Law

Before the Supreme Court was Appellant’s sixth pro se petition requesting that the court reinvest jurisdiction in the trial court in his criminal case to consider a petition for writ of error coram nobis. Also before the court were several pro se motions filed by Appellant. The Supreme Court denied Appellant’s successive petition for coram nobis, denied Appellant’s pro se motions to supplement his successive petition, and declared moot the remaining motions, holding (1) Appellant failed to meet his burden of demonstrating meritorious grounds for the writ; and (2) the additional fact allegations contained in Appellant's pro se motion to supplement his successive petition failed to meet Appellant’s burden of demonstrating a fundamental error of fact extrinsic to the record. View "Jackson v. State" on Justia Law

Appellant was charged by information with three counts of rape, each involving a different occasion and a different victim. The offenses were severed for trial. Appellant was ultimately convicted on all three counts. In the instant habeas corpus petition, Appellant alleged, inter alia, that the trial court was without jurisdiction to impose two of the three sentences. The circuit court dismissed the petition. The Supreme Court affirmed the circuit court’s dismissal of Appellant’s pro se petition for writ of habeas corpus, holding that Appellant failed to allege a basis for the circuit court to grant the writ and demonstrated no clear error in the dismissal of his petition. View "Williams v. Kelley" on Justia Law

Appellant was convicted of capital murder, rape, kidnapping, and residential burglary. Appellant was sentenced to death for the capital murder conviction. The Supreme Court affirmed the judgment of the trial court, holding that the circuit court did not err by (1) denying Appellant’s motion for a directed verdict for the residential-burglary charge; (2) finding that Appellant’s offer to plead guilty to capital murder in exchange for a life sentence was not admissible as a mitigating factor showing Appellant’s acceptance of responsibility for his crimes; and (3) denying Appellant’s motion to suppress his custodial statement. View "Holly v. State" on Justia Law