Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of four counts of computer exploitation of a child in the first degree and of twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The Supreme Court affirmed. Thereafter, Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied relief. Appellant appealed and filed a pro se motion for extension of time to file brief, motion for certified copies of records, and motion to use twelve-point typeface. The Supreme Court dismissed the appeal and declared the motions filed in relation to the appeal moot, holding that Appellant failed to establish that either trial counsel or appellate counsel was ineffective. View "Rea v. State" on Justia Law

In 1969, Appellant pleaded guilty to first-degree murder and was sentenced to life imprisonment. In 2015, Appellant filed a pro se petition for writ of error coram nobis, for correction of sentence, and for declaratory judgment. The trial court treated the petition as a petitio for writ of error coram nobis and denied it. Appellant then filed a motion for new trial seeking reconsideration of his petition because of some alleged incorrect facts in the order. The trial court again denied relief and amended the findings to correct any errors. The Supreme Court affirmed, holding that the trial court did not err in denying relief. View "Mitchell v. State" on Justia Law

After a jury trial, Petitioner was found guilty of second-degree sexual assault. No appeal was taken from the judgment of conviction. Petitioner now sought to proceed with a belated appeal under Ark. R. App. P-Crim. 2(e), arguing that he notified his appointed attorney that he desired to appeal, that it was his belief that a notice of appeal had been filed, and that he was unaware that no appeal had been perfected. The Supreme Court remanded this case because the proper disposition of the motion for belated appeal required findings of fact regarding the issue of whether counsel was informed by Petitioner within the time period allowed for filing a notice of appeal that he desired to appeal. View "Lyons v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder for the death of a fourteen-year-old girl. Appellant was sentenced to life imprisonment without parole. Thereafter, Appellant challenged his conviction by way of direct appeal and federal and state habeas relief, all without success. In 2015, Appellant filed a pro se petition for writ of habeas corpus in the circuit court located in the county in which he is now incarcerated, arguing that the judgment in his case was invalid and that the trial court lacked jurisdiction because the record did not reflect that the jury had found him guilty of either kidnapping or rape, which were the underlying offenses to capital murder. The trial court declined to grant relief. The Supreme Court affirmed, holding that Appellant did not make a showing of probable cause to believe he was illegally detained. View "Heffernan v. State" on Justia Law

Appellant was convicted of second-degree murder and aggravated robbery. The trial court sentenced Appellant to consecutive sentences of thirty years’ imprisonment for each of the charges. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition. Thereafter, Appellant filed a motion seeking that the order be modified to include omitted issues. The trial court denied the motion, concluding that the order had sufficiently addressed the issues. The Supreme Court affirmed, holding (1) the trial court’s order was not inadequate under Ark. R. Crim. P. 37.3(a); (2) the trial court did not clearly err in denying relief on Appellant’s claim that counsel was ineffective for counseling him to reject a plea offer; and (3) the trial court did not misconstrue Appellant’s claim that counsel was ineffective for failing to utilize Appellant’s alleged mental defect and disease at trial. View "Berks v. State" on Justia Law

In 2012, the Arkansas State Police conducted a sobriety checkpoint on an exit ramp on an interstate. Appellant was stopped and subsequently arrested and charged with driving while intoxicated. After a bench trial, Appellant was convicted of driving while intoxicated. Appellant appealed, arguing, inter alia, that the sobriety checkpoint was illegally conducted, requiring reversal of his convictions under the Fourth Amendment. The Supreme Court reversed, holding (1) the sobriety checkpoint was unconstitutional because the State failed to demonstrate that the field officers’ discretion was properly limited; and (2) the seizure of Appellant through the checkpoint stop was unreasonable, and therefore, any evidence obtained as a result of the checkpoint should have been suppressed. View "Whalen v. State" on Justia Law

In 2011, Appellant pleaded guilty to attempted capital murder and kidnapping. In 2015, Appellant filed a petition for writ of error coram nobis, alleging that the prosecutor withheld certain video evidence in violation of Brady v. Maryland, that his guilty plea was coerced, and that he was actually innocent of the charges. The circuit court denied the petition. The Supreme Court affirmed, holding (1) because Appellant could not show that the video was material to and would have altered the outcome of the case, the circuit court did not abuse its discretion in denying the petition; (2) Appellant’s claims of a coerced guilty plea were deficient and unpersuasive; and (3) Appellant’s failure to obtain a ruling by the circuit court on his claim of actually innocence precluded appellate review. View "Thacker v. State" on Justia Law

In 1990, Petitioner was convicted of rape. Petitioner later asked the Supreme Court to reinvest jurisdiction in the trial court so that it may consider whether a writ of error coram nobis. The petition arose from the Department of Justice’s repudiation of testimony of an FBI hair-comparison expert, who testified at Petitioner’s trial. The government admitted that its agent gave invalid expert scientific testimony at Petitioner’s criminal jury trial. The Supreme Court granted the petition, holding that, although Petitioner’s claim may not neatly fall within one of the four established categories, Petitioner stated sufficient grounds for the Court to find that his writ may be meritorious. View "Strawhacker v. State" on Justia Law

Petitioner was convicted of capital felony murder. The conviction was affirmed on appeal. Petitioner later asked the Supreme Court to reinvest jurisdiction in the trial court so that it may consider a writ of error coram nobis, writ of audita querela, or other relief based on newly discovered evidence. The petition arose from repudiated trial testimony of an FBI lab technician, a forensic hair analyst. For the reasons stated in Strawhacker v. State, also released today, the Supreme Court reinvested jurisdiction in the trial court and granted Petitioner permission to seek relief via a writ of error coram nobis. View "Pitts v. State" on Justia Law

Appellant was convicted of first-degree battery and sentenced to ten years in prison. The court of appeals affirmed. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel was ineffective in three ways. After an evidentiary hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that, considering the totality of the evidence, Appellant did not show that counsel’s performance was deficient or that the deficient performance prejudiced his defense, and therefore, the circuit court did not clearly err in denying Appellant’s petition for postconviction relief. View "Doty v. State" on Justia Law