Justia Arkansas Supreme Court Opinion Summaries

Appellant Edward Reynolds appealed after a jury found him guilty of kidnapping and aggravated assault. He was sentenced as a habitual offender to consecutive sentences of life imprisonment and fifteen years’ imprisonment, respectively. On appeal, Reynolds contended that the circuit court erred by: (1) denying his directed-verdict motions on both charges; (2) allowing the victim to testify about her injuries despite the prosecutor’s failure to provide her medical records in discovery; and (3) overruling his objection to remarks made by the prosecutor during closing argument. Finding no error, the Supreme Court affirmed. View "Reynolds v. Arkansas" on Justia Law

In 1994, Petitioner was convicted of the rape of a boy and sentenced to thirty years in prison. The court of appeals affirmed. In 2016, Petitioner filed a petition seeking reinvestment of jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case. Petitioner also filed a motion asking that the petition be granted. The Supreme Court denied the petition and the motion, holding (1) with the exception of the allegations that could possibly be construed as claims that certain material was omitted from the trial record by the State, Petitioner failed to state a ground under which a writ of error coram nobis could issue; and (2) as to Petitioner’s allegations that material was omitted from the trial court, there was no ground for the writ. View "Ashby v. State" on Justia Law

After a jury trial, Petitioner was found guilty of two counts of rape. Petitioner was sentenced to two consecutive terms of twenty years’ imprisonment. Now before the Supreme Court was Petitioner’s fourth pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In his petition, Petitioner raised allegations not raised in the first three petitions, including claims that his judgment of conviction was illegally rendered because of an invalid arrest warrant and an insufficient information. The Supreme Court denied the petition, holding that Petitioner’s allegations were not cognizable in a coram-nobis proceeding and were otherwise without merit. View "Smith v. State" on Justia Law

Appellant filed a request for documents related to his criminal case under the Freedom of Information Act. Appellee, the custodian of records for the Arkansas State Crime Laboratory, denied the request on the grounds that Appellant was an inmate incarcerated in the Arkansas Department of Correction. Thereafter, Appellant sought a hearing before the circuit court and filed a petition to proceed in forma pauperis. The circuit court initially granted the petition but later revoked Appellant’s pauper status and dismissed the case without prejudice, finding that three federal lawsuits should be counted as strikes under Ark. Code Ann. 16-68-607. The Supreme Court reversed, holding that the circuit court erred in counting as strikes cases Appellant filed in federal district court. Remanded. View "Hill v. Gallagher" on Justia Law

Petitioner pleaded guilty to a charge of possession of firearms by certain persons. Petitioner later filed a timely pro se petition pursuant to Ark. R. Crim. P. 37.1 seeking to challenge the judgment. The trial court denied the petition after a hearing. When the record on appeal was tendered to the Supreme Court, the clerk declined to lodge it because it was not received within the required time. Petitioner subsequently filed a motion for rule on clerk seeking permission to proceed with the appeal. The Supreme Court denied the motion, holding that Petitioner failed to demonstrate that he filed a motion for extension of time within the requisite period of time and failed to demonstrate good cause for his failure to comply with the rules of procedure. View "Smith v. State" on Justia Law

After a jury trial, Appellant was found guilty of second-degree battery and of being a felon in possession of a firearm. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court ultimately concluded that Appellant’s claims were not supported by the record. The Supreme Court affirmed, holding (1) the trial court did not clearly err when it denied Appellant’s petition without conducting an evidentiary hearing; and (2) the trial court did not clearly err in concluding that counsel did not provide ineffective assistance. View "Russell v. State" on Justia Law

Petitioner was convicted of first-degree battery and second-degree battery and sentenced to an aggregate sentence of 264 months’ imprisonment. The convictions were affirmed on appeal. Now before the Supreme Court was Petitioner’s second pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and Petitioner’s motion for permission to file a response to the State’s response. The Supreme Court dismissed the petition and declared the motion moot, holding that Petitioner did not establish a basis for issuance of the writ in his first coram-nobis petition, and his reassertion of essentially the same claims in the instant petition was a misuse of the remedy. View "Moten v. State" on Justia Law

Defendant was charged with rape and possession of child pornography. Defendant moved to suppress ten pornographic images of children discovered during a search of his home pursuant to search warrants. The circuit court suppressed the evidence, finding that the absence of time references to when the alleged criminal conduct occurred in the affidavits supporting the application for the warrants made the warrants invalid. The State filed this interlocutory appeal, arguing that “the time of the inculpatory information is not an essential element of probable cause” and that the evidence was admissible under the good-faith exception to the exclusionary rule. The Supreme Court dismissed the appeal, holding that this was not a proper State appeal. View "State v. Sprenger" on Justia Law

Appellant pled guilty to one count of misdemeanor domestic battering in the third degree and three counts of felony terroristic threatening in the first degree. Appellant was placed on probation and ordered to serve 120 days in confinement. Thereafter, Appellant pleaded guilty to violating the terms of his probation. Two years later, Appellant again pleaded guilty to violating the terms of his probation. At issue during sentencing was whether Appellant was entitled to jail-time credit for the time he previously served in confinement when he was first placed on probation. The circuit court ultimately awarded Petitioner thirty-one days’ jail-time credit to account for the time he spent incarcerated between his arrest and the final hearing. The Supreme Court affirmed, holding that Appellant was not entitled to jail-time credit under either Ark. Code Ann. 5-4-404 or Ark. Code Ann. 16-93-309(c). View "Burgess v. State" on Justia Law

Petitioner was convicted of aggravated robbery, residential burglary, and third-degree battery and sentenced to an aggregate term of 540 months’ imprisonment. The court of appeals affirmed. Petitioner later filed the instant motion seeking at public expense a copy of the transcript lodged on direct appeal, stating that he was preparing a petition for writ of habeas corpus to be filed in federal court. Petitioner appended an affidavit of indigency to the motion. The Supreme Court denied the motion, holding that Petitioner failed to establish a compelling need for a copy of the transcript from the direct appeal. View "Bowerman v. State" on Justia Law