Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of aggravated robbery, kidnapping, and theft. Appellant’s convictions and sentences were affirmed on appeal. Appellant later filed a petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, asserting that his sentence was illegal because the trial court sentenced him in excess of the “mandatory sentencing guideline of aggravated robbery” and because he was charged and convicted on offenses based on the same conduct that violated the prohibition against double jeopardy. The circuit court dismissed the action. The Supreme Court dismissed Appellant’s appeal, holding that because Appellant improperly named the director of the Arkansas Department of Corrections as a party and because the State should have been served with the petition but was not, the circuit court had no jurisdiction to make a merit determination on this matter. View "Wesley v. Kelley" on Justia Law

Appellant filed a pro se habeas corpus petition and a petition for leave to proceed in forma pauperis. Thereafter, Appellant filed his notice of appeal in which he sought to appeal what he referred to as a “deemed denied by operation of law habeas corpus petition, and its accompanying intermediate petition to proceed in forma pauperis.” The circuit court subsequently entered an order denying Appellant’s petition to proceed in forma pauperis. Appellant then filed a petition for correction or modification of the record. The Supreme Court (1) denied Appellant’s petition for correction or modification of the record, noting that Appellant’s appeal only concerned the order denying his petition to proceed in forma pauperis; and (2) dismissed the appeal because Appellant failed to address the order denying his petition to proceed in forma pauperis. View "Watts v. Kelley" on Justia Law

Appellant filed a petition for declaratory relief and a writ of mandamus regarding a decision made by the Arkansas Board of Parole rescinding a finding that Appellant was eligible for transfer and a subsequent decision denying Appellant’s transfer eligibility for an additional two-year period. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the Board did not without statutory authority in denying Appellant’s transfer eligibility based on a disciplinary action taken by the Arkansas Department of Correction; but (2) the Board acted outside its authority in denying Appellant’s transfer eligibility by taking into consideration a Sex Offender Community Notification Assessment that was implemented in accordance with the Sex Offender Registration Act. View "Lenard v. Kelley" on Justia Law

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