Justia Arkansas Supreme Court Opinion Summaries

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

After a jury trial, Defendant was found guilty of first-degree murder and sentenced to 420 months’ imprisonment. The court of appeals affirmed on appeal. Thereafter, Defendant filed a pro se petition for writ of habeas corpus, arguing that the evidence was insufficient to support the judgment. The circuit court denied the petition without a hearing on the ground that Defendant had not stated a ground for the writ. The Supreme Court affirmed, holding that the circuit court properly denied the writ because Defendant did not state a ground on which a writ of habeas corpus could be issued. View "Fulton v. State" on Justia Law

After a jury trial, Appellant was found guilty of criminal-attempt first-degree murder and two counts of committing a terroristic act. The court of appeals affirmed Appellant’s convictions and sentences. Appellant later filed in the trial court an amended petition seeking scientific testing under Act 1780 of 2001 Acts of Arkansas specifically requesting as relief that a pair of shoes be tested to prove that he never wore or touched them. The trial court denied Act 1780 relief, finding that the amended petition was not timely and that there was no new scientific testing that was not available at the time of trial or that has since developed that would entitle Appellant to relief. Appellant lodged an appeal and filed a pro se motion for an extension of time to file a complete record on appeal. The Supreme Court dismissed the appeal and declared the motion moot, holding that the trial court did not clearly err in finding that Appellant was not entitled to Act 1780 relief. View "Wells v. State" on Justia Law

Appellant, an inmate, filed a petition seeking judicial review of a decision of the Arkansas Parole Board that denied Appellant’s application for parole. In his petition, Appellant contended that the Board had deprived him of liberty without due process and had retroactively applied a parole statute in violation of the ex-post-facto prohibition in the United States and Arkansas Constitutions. Appellant filed a petition to proceed in forma pauperis in connection with his petition for judicial review. The circuit court summarily denied Appellant’s petition to proceed in forma pauperis on the basis that Appellant had not stated a colorable claim. The Supreme Court affirmed in part, reversed in part, and remanded, holding that Appellant failed to state a colorable claim based on the allegation that the denial of his parole eligibility constituted a violation of his right to due process but did state sufficient non-conclusory facts to assert a colorable claim for judicial review of an alleged violation of the ex-post-facto prohibition, and therefore, Appellant was entitled to proceed in forma pauperis. View "Ruiz v. Felts" on Justia Law