Justia Arkansas Supreme Court Opinion Summaries

Wife appealed a decree entered by the circuit court divorcing her from Husband and contested the denial of her motion for reconsideration. Specifically, Wife argued that the circuit court erred (1) by deciding the parties’ property issues; (2) by modifying their agreement regarding custody and visitation without a hearing; and (3) by omitting from the decree the parties’ agreement for Husband to move to Northwest Arkansas. The Supreme Court reversed, holding (1) the circuit court’s findings on the division of property and debts were clearly erroneous because the court did not conduct a hearing and, rather, accepted Husband’s version of facts and events in dividing the parties’ property and debts; and (2) the circuit court clearly erred by rendering decisions regarding custody and visitation without a hearing. View "Potts v. Potts" on Justia Law

Appellant, a parolee, was charged as a habitual criminal offender with simultaneous possession of drugs and a firearm, possession of methamphetamine with intent to deliver, and possession of drug paraphernalia. Appellant filed a motion to suppress the evidence seized during his arrest on the basis that officers entered his hotel room without a warrant and without knocking and announcing their presence. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the knock-and-announce rule applies to parolees, but the exclusionary rule is not the appropriate remedy; and (2) despite the knock-and-announce violation, the evidence seized from Appellant should not have been suppressed. View "Lane v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of felon in possession of a firearm. On appeal, Appellant argued that the circuit court erred in denying his motion for directed verdict because the State failed to present sufficient evidence that he possessed the firearm and that the circuit court erred in denying his motion for new trial because the State withheld exculpatory evidence from the defense. The Supreme Court affirmed, holding (1) substantial evidence supported Appellant’s conviction for felon in possession of a firearm; and (2) the circuit court did not abuse its discretion in denying Appellant’s motion for new trial. View "Lambert v. State" on Justia Law

Appellant was convicted of rape and theft of a van. Appellant was sentenced to terms of imprisonment and a fine. The Supreme Court affirmed the convictions and sentences. Appellant later filed a petition for a writ of habeas corpus and a motion for the performance of DNA testing seeking testing of a vaginal swab of the victim. Appellant subsequently amended his original habeas petition to include, in addition to his original request for DNA tests, a request for DNA testing of several items. The trial court denied Appellant’s original petition for a writ of habeas corpus, as well as the motion to amend the habeas petition. Now pending before the Supreme Court was Appellant’s motion for belated appeal and rule on clerk. The Supreme Court dismissed the appeal and declared moot the motion seeking to file a belated brief, holding that Appellant could not prevail on appeal because, notwithstanding Appellant’s failure to rebut the presumption that his petition was untimely, Appellant failed to establish that additional testing would significantly advance his claim of innocence. View "Ka Makkali v. State" on Justia Law

After a jury trial, Petitioner was found guilty of five counts of a terroristic act and one count of being a felon in possession of a firearm. Petitioner was sentenced to an aggregate sentence of 1320 months’ imprisonment. Petitioner later filed this pro se petition seeking to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, asserting that there was prosecutorial misconduct based on the State’s reliance on perjured or false testimony and that the State failed to disclose exculpatory evidence in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that Petitioner failed to state grounds for the writ. View "Anderson v. State" on Justia Law

After a jury trial, Petitioner was convicted of one count of capital-felony murder, two counts of aggravated property, and one count of misdemeanor theft of property. Now before the Supreme 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. As grounds for the writ, Petitioner asserted that he had obtained newly discovered evidence in the form of recanted testimony. The Supreme Court denied the petition, holding that the petition was a claim that the evidence adduced at trial was not accurate, and claims of that sort are not within the purview of a coram nobis proceeding. View "Williams v. State" on Justia Law

After a jury trial in 1994, Appellant was found guilty of first-degree murder. Appellant was sentenced to life imprisonment. In 2015, Appellant filed a petition asking the Supreme Court to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, alleging as the basis for his petition a Brady claim. This Court granted Appellant’s petition. The circuit court denied the petition. Appellant appealed. The Supreme Court reversed, holding that the circuit court was required to do more than deny Appellant’s petition without allowing discovery, holding an evidentiary hearing, or making any findings of fact. The Court also granted Appellant’s request to proceed in forma pauperis and appointed counsel. Remanded. View "Williams v. State" on Justia Law

Appellant was convicted of capital murder, aggravated robbery, theft of property, and fleeing. Appellant filed a pro se petition for writ of habeas corpus in the circuit court of the county in which he was incarcerated, alleging that his sentence was illegal, that the evidence against him was insufficient, and that he was actually innocent of the charges. Appellant also filed two motions requesting an extension of time in which to file his brief and seeking en banc review. The Supreme Court dismissed the appeal and declared the motions moot, holding that Appellant failed to allege a basis for the circuit court to grant the writ. View "Jefferson v. Kelley" on Justia Law

Appellant entered a guilty plea to possession of a controlled substance. On the same date, Appellant also entered a guilty plea to delivery of a controlled substance. The court ordered that the sentences in the two cases be served concurrently. Appellant filed a pro se petition to correct an illegal sentence that encompassed both cases but then decided not to proceed with the petition. The court then entered an order granting Appellant’s request to dismiss the petition. Appellant filed a pro se notice of appeal. Now before the Supreme Court was Appellant’s petition for writ of mandamus in which he sought a writ compelling the trial court to correct the order dismissing his petition to correct the sentences in both cases. The Supreme Court dismissed the appeal and declared the mandamus petition moot, holding that Appellant could not succeed if the appeal were allowed to proceed. View "Henry v. State" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery. Petitioner was sentenced to 360 months’ imprisonment. The court of appeals affirmed. After unsuccessfully filing two pro se petitions to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in this case, Petitioner filed this, his third coram-nobis petition. Petitioner also filed a motion for leave to file a response to the State’s response to the petition. The Supreme Court denied the petition and declared moot the motion, holding that Petitioner failed to demonstrate a ground for the writ. View "Carter v. State" on Justia Law