Justia Arkansas Supreme Court Opinion Summaries

Appellant entered a guilty plea to capital murder and was sentenced to life imprisonment without parole. Appellant later filed a pro se petition for writ of error coram nobis, arguing, inter alia, that he was incompetent when he entered the plea and that the plea was coerced. The trial court denied the petition after a hearing. Appellant lodged an appeal and filed a motion to supplement the record. The Supreme Court dismissed the appeal and declared moot the motion, holding that it was clear from the record that Appellant could not prevail if the proceeding went forward because the claims raised by Appellant that were within the purview of the writ failed to establish that the writ should issue. View "Watson v. State" on Justia Law

After a jury trial, Defendant was found guilty of second-degree sexual assault and rape. The Supreme Court affirmed the convictions. Thereafter, Defendant filed original and amended petitions for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting ineffective assistance of counsel. The trial court granted the original and amended petitions for postconviction relief, concluding that counsel provided ineffective assistance and that the court was unable to say that counsel’s failures did not affect the outcome of the sentencing phase. The Supreme Court reversed, holding that the trial court’s finding of prejudice was clearly erroneous. View "State v. Thompson" on Justia Law

Petitioner was convicted of kidnapping and second-degree battery and was sentenced as a habitual offender to concurrent terms of life and 180 months’ imprisonment. The Supreme Court affirmed. Petitioner later filed a petition for writ of habeas corpus, contending that his sentences were inappropriately enhanced under the applicable statute. The circuit court denied the petition. Petitioner later filed this motion requesting permission to proceed with a belated appeal of the circuit court’s order. The Supreme Court dismissed the motion because it was clear the appeal was without merit, holding that none of Petitioner’s claims established a factual basis to support his allegations that the trial court lacked jurisdiction or that the commitment was facially invalid. View "Morgan v. State" on Justia Law

After a jury trial, Petitioner was convicted of second-degree murder and sentenced under a firearm enhancement provision to a total of 540 months’ imprisonment. Now before the Supreme Court were Petitioner’s pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and a motion for appointment of counsel. In support of his claim for coram-nobis relief, Petitioner argued that he was incompetent at the time of trial. The Supreme Court denied the petition, thus mooting the motion for appointment of counsel, holding that Petitioner failed to overcome the presumption that the judgment was valid and failed sufficiently to demonstrate that he acted with diligence in pursuing his claim. View "Hutchinson v. State" on Justia Law

James Toland was arrested on a felony and appeared before a judge who set a sheriff’s bond. Someone on Toland’s behalf paid the ten percent required under the bond. Thereafter, Told and First Arkansas Bail Bonds, Inc. filed suit against the county and two district judges. Appellants subsequently took a voluntary dismissal of their civil rights claims and then took a voluntary dismissal of their claims against the county. The judges filed a motion to dismiss alleging various affirmative defenses. The circuit court granted the motion to dismiss. Toland and First Arkansas Bail Bonds appealed. The Supreme Court dismissed the appeal without prejudice, holding that there was no final order, and therefore, the Court had no jurisdiction to address the merits on appeal. View "Toland v. Robinson" on Justia Law

After a jury trial, Petitioner was found guilty of manufacturing a controlled substance, possession of drug paraphernalia, and being a felon in possession of a firearm. No appeal was taken from the judgment of conviction. Appellant subsequently sought to proceed with a belated appeal arguing that he asked his appointed trial attorney at the time of sentencing to appeal from the judgment but that his attorney failed to file a notice of appeal. The Supreme Court remanded the matter to the trial court for an evidentiary hearing. After the findings of fact and conclusions of law were submitted to the Court, the Supreme Court denied the motion, holding that because the merit of Petitioner’s motion for belated appeal rested entirely on the credibility of the witnesses, the Court accepted the trial court’s findings that Petitioner did not articulate a desire to appeal within the time allowed for counsel to file a timely notice of appeal. View "Siler v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of conspiracy to commit rape. Appellant was sentenced to thirty years’ imprisonment on each count. On appeal, Appellant argued that the circuit court erred by admitting into evidence, during the sentencing phase of his trial, conversations centered on “snuff” sex, which was described as killing someone during or after sex. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion by admitting the evidence, as the evidence regarding snuff sex was both relevant and not unduly prejudicial. View "Shreck v. State" on Justia Law

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