Justia Arkansas Supreme Court Opinion Summaries

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

Petitioner filed a petition for relief under Ark. Code Ann. 16-90-111 that challenged his convictions in four cases. The trial court denied the petition. Petitioner untimely tendered the appeal record, but the Supreme Court granted a motion for rule on clerk to permit the appeal to proceed. Here Petitioner filed a motion for writ of certiorari arguing that the record on appeal as provided to him was incomplete and that certain portions were missing and seeking to have the Court supplement the record. Thereafter, Petitioner filed five additional motions. The Supreme Court (1) remanded for a supplemental record in two of the four cases; (2) dismissed the appeal as to the other two cases; and (3) denied or declared as moot Petitioner’s remaining motions. View "Lukach v. State" on Justia Law

After a jury trial, Petitioner was found guilty of capital murder. Petitioner was sentenced to life imprisonment without parole. The Supreme Court affirmed. This appeal concerned Petitioner’s second petition requesting the Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the petition, holding that none of the claims raised by Petitioner demonstrate that there was some fundamental error at trial or that there existed some fact that would have prevented rendition of the judgment if it had been known to trial court and which was not brought forward before rendition of judgment. View "Hogue v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. Appellant was sentenced as a habitual offender to life imprisonment without the possibility of parole. Thereafter, Appellant filed multiple pro se petitions for postconviction relief, without success. In his fourth pro se petition for a writ of habeas corpus, Appellant asked the circuit court to reconsider allegations set forth in his 2004 pro se petition for writ of habeas corpus in light of the U.S. Supreme Court’s decision Montgomery v. Louisiana. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared the motions moot, holding that the circuit court did not err when it denied the petition. View "Alexander v. Kelley" on Justia Law

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