Justia Arkansas Supreme Court Opinion Summaries

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

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