Justia Arkansas Supreme Court Opinion Summaries

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

After a jury trial, Petitioner was found guilty of nine counts of first-degree battery. No appeal was taken. An amended sentencing order was entered reflecting that Petitioner was sentenced to 3240 months’ imprisonment. Approximately thirty-six months after an amended sentencing order was entered, Petitioner sought leave to proceed with a belated appeal and asked that counsel be appointed to represent him on appeal. The Supreme Court dismissed Petitioner’s motion for belated appeal and declared moot his motion for appointment of counsel, holding that Petitioner did not meet his burden of filing a timely motion within the time period allowed under Ark. R. App. P.-Crim. 2(e). View "Eason v. State" on Justia Law

Petitioner was found guilty of murder in the first degree and abuse of a corpse. Petitioner was sentenced as a habitual offender to an aggregate sentence of life imprisonment. The Supreme Court affirmed. Now before the Court was 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. In his petition, Petitioner asserted, inter alia, that the State suppressed exculpatory evidence in violation of Brady v. Maryland. The Supreme Court denied the petition, holding (1) Petitioner failed to establish a Brady violation; and (2) the remainder of Petitioner’s claims were not cognizable in coram nobis proceedings. View "Williams v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and six counts of terroristic acts. Appellant was also found guilty of using a firearm during the commission of a felony on each count. On appeal, Appellant contended that the circuit court erred in not granting his motions for directed verdict on all charges. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the jury’s inference that Appellant shot at a vehicle with the intent to cause property damage; (2) Appellant had an independent objective to commit terroristic acts, and his intent related to the acts of terrorism, not to murder; and (3) therefore, the circuit court did not err in denying the directed-verdict motions. View "Noble v. State" on Justia Law

Appellant entered a plea of nolo contendere to second-degree sexual assault and was sentenced to 180 months’ imprisonment. Approximately forty-one months after the judgment in his case had been entered, Appellant filed a pro se petition for scientific testing of evidence under Act 1780 of 2001 Acts of Arkansas, as amended by Act 2250 of 2005. The trial court denied the petition, determining that Appellant did not rebut the presumption that it was untimely filed. The Supreme Court affirmed, holding (1) the trial court did not clearly err in determining that the petition was untimely filed; and (2) the trial court correctly ruled in its order denying Appellant’s Act 1780 petition that Appellant had failed to demonstrate a ground for relief under the Act. View "Lewis v. State" on Justia Law

Roby Lowery Stapleton was murdered in 1963. Her murder remains unsolved. In 2013, through the Keech Law Firm, Stapleton’s family made a formal written request to the Department of Arkansas State Police (ASP) for a copy of the case file and other materials relating to ASP’s investigation into Stapleton’s murder. ASP denied the request. Keech then filed a complaint against ASP asking the circuit court to compel disclosure under the Arkansas Freedom of Information Act (FOIA) . ASP maintained that the material was exempt under FOIA because it was the subject of an open and ongoing investigation into Stapleton’s murder. The court ordered ASP to turn over the file, concluding that the case was not an “open and ongoing” law enforcement investigation and, therefore, the claimed exemption did not apply. The Supreme Court affirmed, holding (1) the circuit court’s finding that this investigation was not open and ongoing was not clearly erroneous; and (2) this case falls squarely within the purpose of FOIA. View "Department of Arkansas State Police v. Keech Law Firm P.A." on Justia Law

After a jury trial, Appellant was found guilty of capital murder. Appellant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, raising two claims of ineffective assistance of counsel. The trial court denied relief, concluding that counsel was not ineffective. The Supreme Court affirmed, holding that the trial court’s factual findings support its apparent conclusion that Appellant failed to satisfy either prong of the test set forth in Strickland v. Washington, and those findings were not clearly erroneous. View "Williams v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder. Appellant was sentenced as a habitual offender to life without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, making numerous allegations of ineffective assistance of counsel and an allegation of prosecutorial misconduct. The trial court denied the petition. Appellant appealed and filed two motions related to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that the trial court did not err when it concluded that the conduct of both trial and appellate counsel alleged to be deficient by Appellant did not constitute ineffective assistance of counsel. View "Nichols v. State" on Justia Law