Justia Arkansas Supreme Court Opinion Summaries

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

Appellant entered nolo contendere pleas in two cases. The judgment imposed an aggregate sentence of 360 months’ imprisonment in the two criminal cases, in conjunction with the court’s granting a petition to revoke the suspended sentences. Appellant appealed the revocation order, but the court of appeals affirmed the judgment and granted the appellate attorney’s motion to withdraw. Appellant then filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, alleging ineffective assistance of trial counsel. After an evidentiary hearing, the trial court dismissed the petition. Appellant appealed and also filed motions seeking leave to file a belated reply brief, leave to file a supplemental abstract, and an order for polygraph examinations and to stay the proceedings. The Supreme Court affirmed the denial of postconviction relief and declared the motions moot, holding that trial counsel’s assistance was not constitutionally deficient. View "Flemons v. State" on Justia Law

After a jury trial, Defendant was convicted of second-degree domestic burglary. Defendant was sentenced to five years’ incarceration with an additional one-year enhanced penalty for committing the offense in the presence of a child. Defendant appealed, arguing that the circuit judge abused her discretion by denying Defendant’s motion to recuse and when she denied Defendant’s waiver of a jury trial. The Supreme Court reversed, holding that the circuit judge abused her discretion by not recusing because, under the facts of this case, the judge’s impartiality reasonably could have been questioned by Defendant, and the mandatory provisions of Rule 2.11(A) of the Arkansas Code of Judicial Conduct required her to disqualify. View "Ferguson v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery. Appellant was sentenced as a habitual offender to 720 months’ imprisonment. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was based on numerous claims that his trial attorney was ineffective. Upon remand, the trial court denied postconviction relief after holding a hearing. The Supreme Court affirmed, holding that Appellant did make a showing of ineffective assistance of counsel, and therefore, the trial court did not abuse its discretion in denying postconviction relief. View "Walden v. State" on Justia Law

In 1977, Appellant pleaded guilty to rape and aggravated robbery. Appellant was sentenced to life without parole for the rape conviction. The trial court later granted Appellant’s motion for a new trial and again convicted him of rape and robbery. The Supreme Court affirmed. This appeal concerned Appellant’s petition for writ of habeas corpus, in which Appellant asserted that he received an illegal sentence for rape under Graham v. Florida. Appellant was a juvenile at the time of the offense. The circuit court denied habeas relief. The Supreme Court reversed the denial of Appellant’s habeas petition and issued the writ, holding that Appellant’s rape charge was illegal under Graham. Remanded for entry of a sentence of fifty years on the rape charge. View "Smith v. Kelley" on Justia Law

Appellant pleaded guilty to first-degree murder, criminal attempt to commit first-degree murder, and two enhancements. Appellant was sentenced to fifty-five years’ imprisonment. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, alleging that his counsel provided ineffective assistance and that, but for his counsel’s ineffective assistance, he would not have pleaded guilty and would have gone to trial. After holding an evidentiary hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that counsel performed deficiently and that absent counsel’s deficient performance he would not have entered the guilty plea. View "Jones v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and abuse of a corpose. Appellant was sentenced to life in prison without parole for the murder conviction. Appellant appealed, arguing that the circuit court erroneously denied his motions for directed verdict on the charge of capital murder because the State failed to prove that he committed the murder or that he acted with premeditation and deliberation. The Supreme Court affirmed, holding (1) substantial evidence supported the jury’s decision that Appellant committed the murder; and (2) substantial evidence supported the jury’s determination that Appellant acted with premeditation and deliberation. View "Brooks v. State" on Justia Law

After a jury trial, Petitioner was found guilty of being an accomplice to capital murder. Petitioner was sentenced to life imprisonment without parole. Petitioner’s conviction was affirmed on appeal. Now before the Supreme Court was Petitioner’s pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis or, alternatively, to recall the mandate. In support of his petition Petitioner argued that a supplemental crime-lab report contained material, exculpatory evidence that had been withheld by the prosecution. The Supreme Court denied the petition, holding that the evidence was not withheld by the State prior to Petitioner’s trial and was neither material nor exculpatory. View "Bienemy v. State" on Justia Law