Justia Arkansas Supreme Court Opinion Summaries

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

Appellant pleaded guilty to first-degree murder and rape by forcible compulsion. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his guilty plea was not voluntarily and intelligently made but was, rather, the result of the ineffective assistance of counsel. After an evidentiary hearing, the trial court denied relief based primarily on its credibility findings. Appellant lodged this appeal and filed two motions in which he sought an extension of time to file his brief and also asked the Supreme Court to appoint appellate counsel. The Supreme Court dismissed the appeal and declared Appellant’s motions moot, holding that Appellant failed to establish the first part of the Strickland v. Washington standard, and therefore, the trial court did not err in denying relief. View "Davis v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder. Appellant was sentenced to 480 months in prison. Appellant later filed a verified pro se petition for postconviction relief seeking to vacate the judgment on the ground that his counsel provided ineffective assistance. The trial court denied the petition. Appellant appealed, alleging six grounds for reversal of the trial court’s order. The Supreme Court affirmed, holding that the trial court’s finding were not clearly erroneous and that trial counsel’s assistance was not constitutionally deficient. View "Thompson v. State" on Justia Law

Petitioner was convicted of capital murder based on accomplice liability and was sentenced to life imprisonment without parole. The Supreme Court affirmed, concluding that sufficient evidence supported the conviction based on Petitioner’s confession that he had participating in the murder together with his mother and brother. Now before the Court was Petitioner’s pro se application to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis based on Petitioner’s allegation that the State committed a Brady violation. In support of the allegation, Petitioner attached an affidavit to the petition executed by Petitioner’s mother and stating that she lied about Petitioner’s participation in the murder. The Supreme Court denied the petition, holding that the petition and the attached affidavit failed to establish a basis for coram-nobis relief. View "Wilson v. State" on Justia Law

Appellant was convicted of first-degree murder. The Supreme Court affirmed on appeal. Appellant filed a petition for postconviction relief under Ark. R. Crim. P. 37.1, which was denied. The Supreme Court dismissed Appellant’s appeal. Appellant then filed a pro se petition for writ of habeas corpus, alleging that the judgment was facially invalid because the attorney representing him at trial and on appeal was ineffective and that the judgment was invalid because he was actually innocent. The circuit court denied the petition, concluding that all of Appellant’s claims were grounded in ineffective assistance of counsel and were therefore not cognizable in habeas proceedings. The Supreme Court affirmed, holding that none of Appellant’s claims, whether based on ineffective assistance or on his actual innocence, were cognizable for the writ. View "Mitchell v. Kelley" on Justia Law

Appellant pleaded guilty to two counts of robbery. Appellant was sentenced to an aggregate sentence of 480 months’ imprisonment. Appellant later filed a pro se petition for writ of error coram nobis, a petition for correction illegal sentence in an illegal matter, and a notice of fraud/fraudulent practices, alleging that he was induced into pleading guilty and that counsel failed to present a defense. The trial court denied relief. Now before the Supreme Court was Appellant’s motion for transcribed record and for extension of time to file a brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the trial court did not abuse its discretion in denying the writ. View "Johnson v. State" on Justia Law

Appellant pleaded guilty to four counts of rape and was sentenced to an aggregate sentence of 720 months’ imprisonment. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Civ. P. 37.1. The trial court denied relief. Appellant sought an appeal and then filed a motion for belated appeal and certiorari to complete the record, alleging that the circuit clerk erred by not file-marking his Rule 37.1 petition. The matter was remanded to the trial court. After Appellant's Rule 37.1 petition was file-marked, the trial court denied relief on the grounds that the petition was untimely. The Supreme Court dismissed the appeal and declared the motions Appellant filed in relation to the appeal moot, holding that the trial court properly denied the requested relief. View "Cook v. State" on Justia Law

In 2000, Derrick Price died as a result of a homicide, and a district judge signed Defendant’s arrest warrant for the homicide. Defendant was incarcerated for separate charges of aggravated robbery and attempted first-degree murder. Defendant subsequently pled guilty to aggravated robbery and forgery. In 2014, Defendant was arrested for residential burglary. The next day, fourteen years after the Price homicide, Defendant was arrested for the capital-murder charge. Two days later, the State charged Defendant with capital murder and felon in possession of a firearm. The circuit court dismissed the felony information, concluding that the fourteen-year delay between the arrest warrant being issued and served prejudiced Defendant in violation of his due process rights. The State appealed. The Supreme Court dismissed the appeal, concluding that this was not a proper State appeal. View "State v. Canada" on Justia Law

In 1998, Appellant entered negotiated pleas of guilty to charges of capital murder, first-degree terroristic threatening, and second-degree battery. Appellant received a sentence of life without parole on the capital-murder charge. Appellant later filed a pro se petition for writ of habeas corpus, claiming that the judgment of commitment sentencing him to “life without parole” was facially invalid. The circuit court dismissed the petition, finding that Appellant’s sentence was within the statutory range for capital murder and that Appellant failed to demonstrate probable cause for issuance of the writ. The Supreme Court affirmed, holding that the circuit court did not err in declining to grant relief. View "Millsap v. Kelley" on Justia Law