Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Wofford v. State
The Supreme Court affirmed Defendant's conviction of capital murder and his sentence to life in prison, holding that substantial evidence supported the conviction.After a jury trial, Defendant was convicted of the murder of his ex-wife and sentenced to life imprisonment. As his sole point on appeal, Defendant argued that there was insufficient evidence supporting his conviction, and therefore, the trial court erred in denying his motion for a directed verdict. The Supreme Court disagreed and affirmed, holding that there was substantial evidence to support Defendant's capital murder conviction, and there was no error with respect to the jury's rejection of Defendant's affirmative defense argument. View "Wofford v. State" on Justia Law
Petty v. State
The Supreme Court remanded this case to the circuit court, holding that remand was required to accurately settle the record, specifically concerning Defendant's exhibit 1, a conventionally-filed physical disk that was submitted as part of the record but contained no files.Defendant was convicted of first-degree murder and sentenced to life imprisonment with a fifteen-year enhancement for firearm use. At issue on appeal was whether the circuit court erred in denying Defendant's motion for a mistrial during the guilt phase of trial. The Supreme Court remanded the case, holding that remand was required to rectify gaps in the record. View "Petty v. State" on Justia Law
Posted in:
Criminal Law
Andrews v. Payne
The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition and amended petition for declaratory judgment and writ of mandamus wherein Defendant alleged that the Arkansas Department of Correction illegally changed his discharge date, holding that the circuit court correctly denied the petition and amended petition.After being sentenced in 2007, Defendant was paroled in 2015. Defendant was taken into custody a year later. In his petition and amended petition Defendant alleged that after revocation of his parole and his return to prison, he was informed that his discharge date had been illegally moved. The circuit court denied the petition for failure to state a claim for relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Defendant's petitions for declaratory judgment and writ of mandamus. View "Andrews v. Payne" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
Tilson v. State
The Supreme Court denied a petition for writ of certiorari and/or prohibition requesting relief from the Court after the circuit court denied Petitioner's motions to dismiss the charges against him, holding that an extraordinary writ was not necessary in this case.Petitioner, who was charged with aggravated robbery and other charges, moved to dismiss the charges for a violation of his right to a speedy trial pursuant to Ark. R. Crim. P. 28.1, asserting that he was not brought to trial within twelve months from the date of his arrest. Petitioner also filed a motion to dismiss for lack of jurisdiction, alleging that the juvenile division retained exclusive jurisdiction. The circuit court denied both motions. The Supreme Court denied Petitioner's ensuing petition for writ of certiorari and/or prohibition, holding that the circuit court did not err in denying Petitioner's motions to dismiss for lack of jurisdiction and for violation of his speedy-trial rights. View "Tilson v. State" on Justia Law
Carroll v. Payne
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's two petitions for declaratory judgment and writ of mandamus wherein Appellant asked the circuit court to declare that he was entitled to parole and to direct his release on parole from the Arkansas Division of Correction (ADC), holding that there was no error.Appellant filed petitions for declaratory judgment and writ of mandamus asserting that the ADC violated Ark. Code Ann. 16-93-615(h), which was codified as section 16-93-1302(f) at the time Appellant committed the crime of rape, by denying him parole. The circuit court dismissed the petition, concluding that the issues raised therein was been addressed and resolved in Carroll v. Hobbs, 442 S.W.3d 834 (Ark. 2014). The Supreme Court affirmed, holding that the circuit court did not clearly err or abuse its discretion by denying and dismissing Appellant's petitions for declaratory and mandamus relief. View "Carroll v. Payne" on Justia Law
Posted in:
Criminal Law
Todd v. State
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err.In his section 16-90-111 petition, Petitioner alleged that consecutive sentences imposed upon revocation of suspended sentences in eight separate cases were illegal. Ark. R. Crim. Code 37.2(c) required Petitioner to file a Ark. R. Crim. Code 37.1 petition challenging the revocation of his suspended sentences within sixty days of the mandates issued by the court of appeals in May and July 2016. Petitioner, however, filed his petition to correct an illegal sentence almost four years later, in February 2020. The circuit court denied and dismissed the petition because Rule 37.1 had superseded it, and Petitioner's petition was untimely. The Supreme Court affirmed, holding that Petitioner was not entitled to relief. View "Todd v. State" on Justia Law
Posted in:
Criminal Law
Harmon v. State
The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition to correct an illegal sentence, holding that Petitioner failed to establish either that his sentence was illegal on its face or, at the time of sentence, that the sentencing court lacked subject-matter jurisdiction.Petitioner pleaded guilty to manslaughter and robbery and stipulated that he was a habitual offender. Petitioner was sentenced to sixty months in prison for manslaughter and 480 months for robbery, with his sentences to run consecutively. Petitioner later filed a petition for relief from an illegal sentence, which the circuit court denied. The Supreme Court affirmed, holding that Defendant's sentence fell within the maximum prescribed sentence and was legal on its face and that the circuit court did not clearly err in denying Petitioner's petition on all grounds. View "Harmon v. State" on Justia Law
Posted in:
Criminal Law
Davis v. Payne
The Supreme Court granted Petitioner's pro se petition for a writ of mandamus directing Honorable Quincy Ross, circuit judge, to issue an order acting on Petitioner's habeas petition within thirty days of the date of this opinion, holding that Petitioner was entitled to the writ.Petitioner pleaded guilty to theft of property and was sentenced to sixty months' imprisonment as a habitual offender. In his mandamus petition, Petitioner asserted that Judge Ross had failed timely to act on his petition for writ of habeas corpus. The Supreme Court granted the writ because Petitioner's habeas petition had been pending since 2021, no action had been taken, and the State's response offered no explanation for the extended delay. View "Davis v. Payne" on Justia Law
Posted in:
Criminal Law
Gonder v. State
The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to vacate and dismiss judgment and commitment order due to lack of jurisdiction filed under Ark. Code Ann. 16-90-111, holding that there was no error.In his motion, Appellant argued that the trial court lacked jurisdiction to convict him because he did not engage in the criminal conduct contemplated by Ark. Code Ann. 5-54-119 and because the elements of section 5-54-119 were not established. The Supreme Court affirmed the trial court's denial of the motion, holding that the trial court did not clearly err when it found that Appellant did not state a cause of action under section 16-90-111(a). View "Gonder v. State" on Justia Law
Posted in:
Criminal Law
Mitchell v. State
The Supreme Court affirmed the judgment of the circuit court convicting and sentencing Defendant for first-degree battery and failure to appear on a felony, holding that the circuit court did not abuse its discretion by denying Defendant's motion to substitute counsel and that there was substantial evidence to support Defendant's conviction for first-degree battery.After a three-day trial, the jury convicted Defendant of first-degree battery and failure to appear but acquitted him of second-degree battery. The Supreme Court affirmed, holding (1) because Defendant was indigent he was not entitled to the counsel of his choice, and therefore, the circuit court did not abuse its discretion in denying Defendant's motion to substitute counsel; and (2) the State introduced substantial evidence sufficient to support Defendant's conviction for first-degree battery. View "Mitchell v. State" on Justia Law
Posted in:
Criminal Law