Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of capital murder, two counts of aggravated robbery, and two counts of kidnapping. Defendant elected to forgo sentencing by the jury. The State did not seek the death penalty for the capital murder conviction, for which Defendant automatically received a life sentence without parole. The circuit court sentenced Defendant as a habitual offender to concurrent terms of life imprisonment for the remaining offenses. The Supreme Court affirmed, holding that, by making certain rulings, the circuit court did not deny Defendant (1) the right to self-representation, (2) the right of confrontation, or (3) the right to the assistance of counsel. View "Dennis v. State" on Justia Law

Petitioner pleaded guilty to delivery of a counterfeit substance and delivery of a controlled substance. Petitioner later filed a pro se petition to correct or reduce his sentence. The trial court denied the petition. Petitioner timely filed a pro se notice of appeal but did not tender the record on appeal to the Supreme Court in accordance with the rules of procedure. Petitioner now sought to proceed with a belated appeal, a motion the Supreme Court treated as a motion for rule on clerk to lodge the record belatedly. The Supreme Court then denied the motion, holding that Petitioner did not state good cause for his failure to timely tender the record to the Court. View "Billings v. State" on Justia Law

The facts related to this appeal stemmed from Attorney Theodis N. Thompson Jr.’s representation of Michael Baker on criminal charges. The circuit court found Thompson in criminal contempt for his failure to appear at a scheduled hearing and sentenced him to twenty-four hours imprisonment in the county jail. After Thompson served his sentence, he appealed, arguing that his right to due process was violated because he was deprived of proper notice of the criminal contempt charge. The Supreme Court reversed, holding (1) the mootness doctrine did not bar Thompson’s direct appeal of his criminal contempt conviction; and (2) the State failed to establish that Thompson received notice of the accusation of contempt for his failure to appear at the scheduled hearing. View "Thompson v. State" on Justia Law

In 1998, Appellant pleaded guilty to capital murder, terroristic threatening, and second-degree battery. Appellant was sentenced to life imprisonment without the possibility of parole for the murder conviction. In 2015, Appellant filed in the trial court a second pro se petition for coram-nobis relief, alleging that he was insane at the time of trial, that the prosecutor withheld evidence of Appellant’s insanity in violation of Brady v. Maryland, and that his guilty plea was coerced. The trial court denied relief. The Supreme Court dismissed Appellant’s appeal, holding that Appellant failed to state grounds for the issuance of a writ of error coram nobis. View "Millsap v. State" on Justia Law

In 1979, Appellant pleaded guilty to murder in the first degree and was sentenced to imprisonment for the “rest of his natural life.” In 2014, Appellant filed in the trial court a petition for writ of error coram nobis or motion to correct clerical error or mistake in judgment-and-commitment order, alleging, inter alia, that the trial court made false statements regarding his sentence during the plea hearing that made his sentence illegal and that his trial counsel provided ineffective assistance. The trial court denied Appellant’s claim for relief. The Supreme Court dismissed Appellant’s appeal, holding that Appellant failed to establish that he exercised due diligence in bringing forth his claims, and even assuming Appellant had been diligent in bringing his claims, he failed to establish that he was entitled to relief. View "Green v. State" on Justia Law

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