Justia Arkansas Supreme Court Opinion Summaries

In 1991, Appellant pleaded guilty to aggravated robbery and several other offenses, for which he was sentenced to an aggregate term of fifty years’ imprisonment. In 2015, Appellant filed a motion to correct time spent in custody. The trial court denied the motion, concluding that Appellant’s request for jail-time credit against his sentence was a request for modification of a sentence imposed in an illegal manner, and, as such, Appellant failed to timely seek postconviction relief under Ark. R. Crim. P. 37.1. The Supreme Court reversed, holding that while the Court would orindary hold that a request for jail-time credit was arequest for modification of a sentence, under the circumstances of this case, Appellant established that there was evidence of a scrivener’s or omission error on his judgment. Remanded for the trial court to examine whether the evidence was sufficient to entitle Appellant to relief pursuant to Ark. R. Civ. P. 60(b). View "Cason v. State" on Justia Law

After a jury trial, Petitioner was convicted of rape, aggravated robbery, and burglary. Petitioner was sentenced as a habitual offender to consecutive terms of life imprisonment for rape and an aggregate sentence of forty years’ imprisonment for the other offenses. The Supreme Court affirmed. Thereafter, Petitioner filed numerous filings challenging his conviction, all of which were unsuccessful. In 2011, Petitioner filed in the Supreme Court a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, asserting a violation of the requirements of Brady v. Maryland. The petition was denied. Now before the Supreme Court was Petitioner’s second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging yet another Brady violation. The Supreme Court denied the petition, holding that Petitioner failed to prove a Brady violation because he failed to demonstrate that there was a reasonable probability that the judgment of conviction would not have been rendered had the information been disclosed at trial. View "Carter v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and aggravated-residential burglary. Appellant appealed, arguing that the trial court erred in finding that the victim was competent to testify. The court of appeals affirmed. Thereafter, Appellant filed a pro se petition for postconviction relief alleging, inter alia, that both trial counsel and appellate counsel had provided ineffective assistance of counsel. The trial court denied relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that the trial court did not abuse its discretion when it denied relief without conducting a hearing, and Appellant offered no argument demonstrating that the trial court’s findings were clearly erroneous. View "Wooten v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of rape. Appellant was sentenced to a term of 120 months’ imprisonment on each count, to be served consecutively. Thereafter, Appellant field a timely, verified petition for postconviction relief under Ark. R. Crim. P. 36.1, alleging that he was serving an illegal sentence, and a memorandum of law in support of the motion. The trial court denied the relief sought. The Supreme Court affirmed, holding that the trial court did not err in denying relief because Appellant failed to meet his burden of demonstrating in his petition that his sentence was illegal. View "Thompson v. State" on Justia Law

After a jury trial, Appellant was convicted of rape. Appellant was sentenced as a habitual offender to life imprisonment. Appellant appealed, arguing that the evidence was insufficient to support his conviction and that the trial court erred when it refused to submit the jury verdict form by interrogatories. The Supreme Court affirmed, holding (1) there was substantial evidence of rape under alternate theories of the case sufficient to support the conviction; and (2) because Appellant presented to citation or authority in support of his argument that the court erred when it refused to submit the jury verdict form by interrogatories and because it was not apparent without further research that his argument was well taken, Appellant’s second point on appeal will not be considered. View "Ortega v. State" on Justia Law

Appellant pleaded guilty to fourth-degree sexual assault and was sentenced to seventy-two months’ imprisonment. Appellant subsequently filed multiple pleadings in the trial court, all of which essentially claimed that he was serving an illegal sentence because he was not serving his state sentence in federal custody as per his plea agreement. The trial court denied Appellant’s claims for relief in three separate orders. Appellant appealed the three orders. Now before the Supreme Court were Appellant’s motions for extension of time to file brief and for appointment of counsel. The Supreme Court dismissed the appeal, which rendered the motions moot, holding that the trial court did not err in denying relief. View "Malone v. State" on Justia Law

After a jury trial, Appellant was convicted of rape. Appellant was sentenced to twenty-three years’ imprisonment. Appellant later filed a petition for postconviction relief, asserting eleven claims of ineffective assistance of trial counsel. The circuit court denied the petition without holding an evidentiary hearing. Appellant appealed, arguing that he was entitled to an evidentiary hearing on five claims raised in his petition. The Supreme Court affirmed the circuit court’s order, holding that Appellant was not entitled to postconviction relief and that the circuit court did not err in denying his petition without a hearing. View "Luper v. State" on Justia Law

Appellant filed in the Circuit Court of Lincoln County a pro se petition for writ of habeas corpus. At the time he filed the petition, Appellant was incarcerated at a unit of the Arkansas Department of Correction located in Lincoln County. Appellant was subsequently relocated to a work program located in Miller County. The Lincoln County Circuit Court dismissed Appellant’s habeas-corpus petition without prejudice. The Supreme Court dismissed Appellant’s appeal, holding that because Appellant was no longer incarcerated in Lincoln County, the Circuit Court of Lincoln County did not have jurisdiction to grant the relief sought. View "Jones v. Kelley" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery, theft of property, and being a felon in possession of a firearm. The court of appeals affirmed. Petitioner later filed a pro se petition seeking reinvestment of jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case, claiming that the State violated Brady v. Maryland during the trial proceedings. The Surpeme Court denied the petition, holding that Petitioner failed to establish a Brady violation and failed to state a ground within any of the other categories under which a writ of error coram nobis is proper. View "Evans v. State" on Justia Law

After a jury trial, Petitioner was found guilty of aggravated robbery. Petitioner was sentenced to 360 months in prison. The court of appeals affirmed. Petitioner later filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case, alleging that the State violated Brady v. Maryland. The Supreme Court denied the petition, concluding that the claims raised by Petitioner were challenges to the sufficiency of the evidence rather than a Brady violation. Now before the Supreme Court was Petitioner’s second coram nobis petition, in which he reiterated his Brady claim. The Supreme Court denied the petition, holding, as with the first petition, that Petitioner failed to establish a ground to issue a writ of error coram nobis. View "Carter v. State" on Justia Law