Justia Arkansas Supreme Court Opinion Summaries

Defendant pleaded guilty to charges from several different cases, including first-degree murder, aggravated robbery, and first-degree escape. Defendant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due to his counsel’s failure to request a competency hearing. The circuit court denied relief, concluding that trial counsel made a reasonable decision not to pursue the competency question further, and that decision did not prejudice Defendant. The Supreme Court affirmed, holding that Defendant did not satisfy the Strickland v. Washington test for ineffective-assistance-of-counsel claims under Rule 37.1. View "Beverage v. State" on Justia Law

After a jury trial, Appellant was found guilty of manslaughter. Appellant was sentenced to ten years’ imprisonment. The Supreme Court affirmed in part and reversed and remanded in part for a new trial, holding that the circuit court (1) did not err by excluding testimony about the victim’s character and previous acts of violence; (2) prejudicially erred by refusing to declare a mistrial when it was discovered that the court’s bailiff had barred members of Appellant’s family from the courtroom during voir dire; and (3) did not abuse its discretion by refusing to give instructions on negligent homicide and imperfect self-defense. View "Schnarr v. State" on Justia Law

After a jury trial, Defendant was convicted of driving while intoxicated (DWI) and failure to submit to a chemical test. The Supreme Court affirmed, holding (1) the State presented substantial evidence to support the convictions; (2) the police officer that pulled Defendant over had probable cause to believe that the vehicle violated a traffic law, and therefore, the trial court properly denied Defendant’s motion to suppress; (3) Defendant’s argument that the court’s denial of Defendant’s motion for posttrial relief regarding his sentence was not preserved for appellate review; (4) the criminal information was not defective; and (5) evidence of Defendant’s two prior DWI convictions was properly admitted. View "Lockhart v. State" on Justia Law

Defendant entered a negotiated plea of nolo contendere to rape and was sentenced to 180 months’ imprisonment. Defendant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 seeking to have the judgment vacated on the ground that his counsel provided ineffective assistance. The trial court denied relief. Defendant appealed and filed a motion for a “default judgment” and appointment of counsel. The Supreme Court affirmed the trial court’s order denying the Rule 37.1 petition and declared moot the motion seeking a default judgment and appointment of counsel, holding that the Rule 37.1 petition lacked facts to support Defendant’s claims of ineffective assistance of counsel. View "Hansler v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and tampering with physical evidence. Appellant was sentenced to life imprisonment. The convictions were affirmed on appeal. Appellant subsequently filed a petition for relief under Ark. R. Crim. P. 37, alleging that he received ineffective assistance of counsel.The circuit court denied Appellant’s petition after a hearing. Thereafter, Appellant filed a motion to reconsideration alleging that he had found evidence that contradicted testimony given at the hearing. The court denied the motion. The Supreme Court affirmed, holding (1) the trial court did not err by denying Appellant’s petition; and (2) the trial court did not err by denying Appellant’s motion for reconsideration. View "Hartman v. State" on Justia Law

After a jury trial, Petitioner was found guilty of first-degree murder, theft of property, and false imprisonment. The trial court sentenced him to an aggregate term of life imprisonment. Two decades later, Petitioner filed a second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, arguing that the State violated Brady v. Maryland. Petitioner reiterated some of the grounds considered by the Supreme Court in his first coram-nobis petition. The Supreme Court denied relief, holding that Petitioner did not establish a Brady violation. View "Davis v. State" on Justia Law

Appellant pleaded guilty to two counts of rape and was sentenced to an aggregate sentence of 480 months’ imprisonment. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging various grounds of ineffective assistance of counsel. The trial court denied relief. Thereafter, Appellant filed a second Rule 37.1 petition. Now before the Supreme Court was Appellant’s motion for extension of time to file a brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the trial court properly denied Appellant’s request for postconviction relief because Appellant attempted to raise claims in an unauthorized second Rule 37.1 petition and because the petition was untimely. View "Woods v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and second-degree sexual assault. Appellant was sentenced as a habitual offender to an aggregate term of 960 months’ imprisonment. The court of appeals affirmed. Appellant later filed this pro se petition for writ of habeas corpus seeking to have the judgment vacated or to be resentenced, arguing that there was insufficient evidence to sustain the judgment and that his sentence violated the Eighth Amendment. The trial court denied relief. The Supreme Court affirmed, holding that the petition did not allege any basis for relief proper in a habeas proceeding. View "Clayton v. Kelley" on Justia Law

In 2015, Appellant was convicted of capital felony murder and sentenced as a habitual offender to life imprisonment without parole. The Supreme Court affirmed. In 2016, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Because the petition did not comply with the requirements of Rule 37.1(b), the trial court dismissed it. Appellant brought this appeal and also filed a petition for writ of certiorari to supplement the record on appeal. The Supreme Court affirmed the dismissal of the Rule 37.1 petition, which rendered the petition for writ of certiorari moot, holding that the trial court did not abuse its discretion in dismissing the petition. View "Felty v. State" on Justia Law

Appellant pleaded guilty to one count of manslaughter. The Arkansas Department of Corrections (ADC) initially calculated Appellant’s term of imprisonment to total an aggregate term of 240 months’ imprisonment. However, the ADC changed Appellant’s time computation card to reflect the time to be served as an aggregate term of 360 months’ imprisonment. Appellant filed a petition for judicial review, alleging that the ADC had interpreted the sentencing order to illegally extend the duration of his incarceration. The ADC alleged that the circuit court had entered an amended sentencing order that increased the aggregate sentence to 360 months’ imprisonment but failed to include this amended order in the record. The ADC subsequently supplemented the record with a certified copy of the amended sentencing order. The circuit court dismissed the action. The Supreme Court affirmed but remanded, holding that because the amended sentencing order had the effect of extending Appellant’s parole eligibility date and in view of the fact that the ADC conceded that the amended order imposed a sentence that exceeded the maximum statutory penalty, it was likely that Appellant was being wrongfully detained. Remanded to the circuit court to vacate the amended sentencing order. View "Ward v. Kelley" on Justia Law