Justia Arkansas Supreme Court Opinion Summaries

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

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