Justia Arkansas Supreme Court Opinion Summaries

Appellant was convicted of raping a mentally handicapped sixteen-year-old girl. Appellant was sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed in the trial court a pro se petition under Ark. R. Crim. P. 37.1 and motion for error coram nobis. On appeal, Appellant argued that his postconviction petition was not untimely, contrary to the trial court’s holding, because the postmark on his petition indicated that it was mailed well before the due date and that the file mark was a clerical error. The Supreme Court affirmed in part and reversed in part, holding (1) under the facts and circumstances of this case, Appellant’s Rule 37.1 and coram-nobis petition should have been filed prior to the filing deadline, and the matter is remanded for the circuit court to file-mark Appellant’s Rule 37.1 petition with the appropriate date; and (2) the trial court properly dismissed Appellant’s coram-nobis petition. View "McClinton v. State" on Justia Law

Appellant pleaded guilty to second-degree sexual assault and was sentenced to 144 months’ imprisonment. Thereafter, Appellant filed an untimely petition for postconviction relief under Ark. R. Crim. P. 37.1. The circuit court denied the petition on the ground that it was untimely. Appellant lodged an appeal in the Supreme Court. Now before the Court were Appellant’s pro se motions requesting files generated by his trial counsel and also counsel that Appellant alleged represented him in matters involving the Arkansas Department of Human Services. In violation of Ark. R. Crim. P. 19(b), counsel failed to file responses with the Supreme Court. Therefore, the Court directed trial counsel and counsel at issue to file a response with the Court within twenty days from the date of this opinion. View "Geatches v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of delivery of cocaine and one count of delivery of a counterfeit substance. Appellant was sentenced to 552 months’ imprisonment. The court of appeals affirmed. In separate proceedings later that same year, Appellant was convicted of fleeing apprehension and leaving the scene of a personal injury accident. Appellant was sentenced to 360 months’ imprisonment, to run consecutively to the sentences imposed in the earlier conviction. Appellant filed pro se petitions for postconviction relief as to both judgments. The trial court consolidated the proceedings and denied both petitions. The Supreme Court affirmed, holding that the trial court did not err or clearly err in denying postconviction relief on Appellant’s claims. View "Flemons v. State" on Justia Law

After a jury trial, Petitioner was found guilty of several drug offenses. Petitioner was sentenced to a term of life imprisonment on the charge of possession of cocaine with intent to deliver, to be served consecutively to his remaining sentences. 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 the State violated his right to due process during trial pursuant to Brady v. Maryland. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate a Brady violation that warranted issuance of a writ of error coram nobis. View "Carter v. State" on Justia Law

After a jury trial, Appellant was convicted of one count of capital felony murder and sentenced to death. The Supreme Court affirmed, holding that the circuit court (1) did not violate Appellant’s right to a fair and impartial jury trial by allowing Appellant’s entire “pen pack” to be submitted to the jury; (2) did not violate Appellant’s due process rights by limiting defense counsel's questions to potential jurors; (3) did not improperly remove jurors for cause; (4) did not err in granting the State’s motion for a mental-health evaluation of Appellant; (5) did not err in refusing to allow certain jury instructions proffered by the defense; (6) did not err in denying Appellant’s proffered jury instruction regarding “lingering doubt” as a mitigating circumstance; and (7) did not err in refusing to allow Appellant to introduce as a mitigating circumstance that Appellant had a calming influence on others while in custody. View "Gay v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of second-degree murder and one count of attempted second-degree murder. Appellant received a combined term of thirty-eight years’ imprisonment for these convictions. Appellant appealed, arguing that the circuit court erred by failing to grant his motions for directed verdict because the evidence did not demonstrate that he was the perpetrator of the offenses and that the State’s theories of the murders were not supported by the evidence. The Supreme Court affirmed Appellant’s convictions and sentences, holding that the jury’s verdicts were supported by substantial evidence. View "Howard v. State" on Justia Law

Petitioner entered a plea of guilty to theft by receiving and was sentenced o sixty months’ imprisonment to be followed by a suspended imposition of sentence for thirty-six months. Petitioner’s suspended sentence was later revoked, and he was sentenced to 420 months’ imprisonment. The court of appeals affirmed. Petitioner subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition. Now before the Supreme Court as Petitioner’s pro se motion for rule on clerk to lodge the record belatedly. The Supreme Court denied the request to proceed with the appeal because Petitioner did not state good cause for his failure to timely tender the record to the Supreme Court in accordance with the prevailing rules of procedure. View "King v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and first-degree battery. Defendant was sentenced to an aggregate sentence of sixty-five years’ imprisonment. The court of appeals affirmed. Thereafter, Defendant filed a petition for postconviction relief pursuant to Ark. R. Civ. P. 37.1, in which he asserted numerous claims of ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that the circuit court did not err in denying Defendant’s claims that his appellate counsel provided ineffective assistance and that his trial counsel provided ineffective assistance. View "Liggins v. State" on Justia Law

In 1982, judgment was entered reflecting that Appellant pleaded guilty to capital felony murder and was sentenced to life imprisonment without parole. In 2016, Appellant filed a pro se petition for writ of error coram nobis asserting that he was mentally incompetent at the time he entered his plea and that the was coerced and threatened into changing his plea of not guilty by reason of mental disease to a plea of guilty. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant’s petition did not state a ground to warrant issuance of a writ of error coram nobis and that Appellant was not diligent in bringing the petition. View "Matthews v. State" on Justia Law

Appellant was found in criminal contempt for failing to appear as counsel at his client’s jury trial. Appellant appealed, arguing that he could not be held in contempt for willfully violating the trial court’s scheduling order because he was under subpoena in another court and that the court’s decision to deny Appellant’s motion to delay the trial rendered the court’s underlying scheduling order invalid. The Supreme Court affirmed, holding that substantial evidence supported the court’s contempt finding and that the failure to appear in one court due to a conflict in another can still amount to willful contempt. View "Valley v. State" on Justia Law