Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted as an accomplice to capital murder and kidnapping. Defendant was sentenced to life without parole for the murder conviction and to a term of twenty-five years for kidnapping. The Supreme Court affirmed. Defendant then filed a petition for postconviction relief, alleging ineffective assistance of counsel and that her life sentence for capital murder was disproportionate to the crime charged. The circuit court rejected Defendant’s petition. The Supreme Court affirmed, holding (1) the circuit court did not clearly err when it concluded that Defendant received effective assistance of counsel; and (2) because Defendant failed to raise her arguments regarding her sentence at trial, she must show fundamental error, and the facts presented here did not involve a fundamental error. View "Swain v. State" on Justia Law

After a jury trial, Petitioner was found guilty of murder. Petitioner was sentenced to life imprisonment without parole. The Supreme Court affirmed. Petitioner field a petition for coram nobis relief, alleging, inter alia, a Brady violation. The Supreme Court denied relief. Petitioner now filed in the Court a second pro se petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis. In his second petition, Petitioner set forth eleven grounds eleven grounds for relief. The Supreme Court denied the petition, holding that Petitioner’s claims were either without merit, conclusory, or not cognizable in coram nobis proceedings. View "McArthur v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to life without parole. The Supreme Court affirmed the judgment. Thereafter, Petitioner was convicted of first-degree murder and sentenced as a habitual offender to 720 months’ imprisonment to be served consecutively to the life sentence. Now before the Supreme Court was Petitioner’s second petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis in the capital murder case. In his petition, Petitioner alleged that the prosecutor withheld exculpatory evidence with respect to both convictions. The Supreme Court denied the petition, holding that Petitioner failed to state sufficient grounds in support of his petition. View "Hill v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The jury found Appellant had used a firearm in the commission of that murder. At trial, Appellant filed a motion for new trial following the discovery of two Facebook posts created by two of the State’s witnesses. The circuit court denied the motion. On appeal, Appellant challenged only the denial of his motion for a new trial, arguing that the post was newly discovered evidence that would have materially changed the outcome of Appellant’s trial in his favor had it been available to the jury. The Supreme Court affirmed, holding that the evidence did not satisfy the standard for newly discovered evidence. View "Johnson v. State" on Justia Law

Appellant was charged with one count of battery in the first degree and one count of battery in the second degree. The first jury trial resulted in a mistrial. The circuit court entered a revised scheduling order setting a new trial date. Appellant moved to dismiss alleging a speedy-trial violation. The circuit court denied the motion to dismiss. After a second trial, the jury convicted Appellant as charged and sentenced him to thirty years’ imprisonment and fifteen years’ imprisonment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Appellant’s motion to dismiss based on an alleged speedy-trial violation, and (2) denying Appellant’s motion to appear at trial in civilian clothing rather than prison garb. View "Hinton v. State" on Justia Law

After a jury trial, Petitioner was found guilty of the rape of a child. Petitioner was sentenced to 432 months’ imprisonment. The court of appeals affirmed. Petitioner later filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case, claiming that there was prosecutorial misconduct in his trial, that the trial court made some mistake in its rulings, and that the evidence at his trial was not sufficient to sustain the jury’s verdict. The Supreme Court denied the petition, holding that Petitioner failed to assert a ground for the writ. View "Henington v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder, aggravated robbery, and theft of property. In a separate trial, Appellant was found guilty by a jury of an additional aggravated robbery. Appellant later filed a pro se petition for writ of habeas corpus, arguing that he was not properly advised of his Miranda rights when he was interrogated by the police. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant did not state a ground on which a writ of habeas corpus should be issued and that the circuit court was not clearly erroneous in denying habeas relief without a hearing. View "Davis v. Kelley" on Justia Law

After a jury trial, Petitioner was found guilty of first-degree murder. Petitioner was sentenced to 300 months’ imprisonment. The court of appeals affirmed. Now before the Supreme Court was Petitioner’s pro se petition to recall the mandate to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis. The Supreme Court denied the petition, holding that none of the claims raised by Petitioner fell within the purview of a coram nobis proceeding because they were not errors found in one of the four categories of error. View "Strain v. State" on Justia Law

Appellant, an inmate, filed a complaint against twenty-two employees of the Arkansas Department of Corrections alleging violations of his civil rights. Specifically, Appellant claimed that he was denied access to certain religious publications and the right to lead Nation of Islam religious services. Appellant filed a pro se motion for a preliminary injunction, summary judgment, and default judgment seeking to enjoin Defendants from violating his rights. The circuit court denied the motion without holding a hearing on the merits. Appellant appealed the denial of his motion for summary judgment and a preliminary injunction. The Supreme Court (1) dismissed Appellant’s appeal from the motion for summary judgment, as a denial of a motion for summary judgment is not a final, appealable order; and (2) reversed and remanded to the circuit court to hold a hearing on Appellant’s motion for preliminary injunction, holding that, under the circumstances of this case, the complexity and the rights in question warranted a hearing below. View "Muntaqim v. Hobbs" on Justia Law

Appellant pleaded guilty to second-degree murder and was sentenced to an aggregate sentence of fifty-five years’ imprisonment. Defendant later filed a petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, alleging that the sentence reflected on the judgment imposed for second-degree murder was outside of the statutory range, that the judgment was facially invalid, and that the sentence must be corrected. The trial court denied the petition. The Supreme Court affirmed but remanded with instructions, holding (1) the trial court’s findings that Appellant was sentenced as a habitual offender and that the sentence imposed was not illegal were not clearly erroneous; but (2) because the trial court found that Appellant was sentenced as a habitual offender, and the box that would indicate that Appellant was sentenced as a habitual offender was not checked on the judgment, the trial court should have corrected the judgment to accurately reflect Appellant’s habitual-offender status. View "Mohammed v. State" on Justia Law