Justia Arkansas Supreme Court Opinion Summaries

Appellant, who was convicted of rape, filed a pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111. The trial court denied the petition. Appellant appealed. The Supreme Court found good cause to reverse without considering Appellant’s arguments concerning the merits of his petition for relief under the statute. The court held that because the judge who ruled on Appellant’s section 16-90-111 petition was, in fact, the prosecuting attorney at his trial for rape, a serious appearance impropriety was created because the judge did not refrain from presiding over a case in which he might be interested. The court remanded the matter so that a different circuit judge can rule on the petition. View "Latham v. Kelley" on Justia Law

After the underlying business dispute proceeded to arbitration, Appellees filed in the circuit court a petition to enforce the award, and Appellant filed a cross-petition to vacate the award. The circuit court confirmed the award. Appellant appealed, arguing that the arbitrator lacked the authority to hear the case under either federal or Arkansas law and that the award should have been vacated on public policy grounds. The Supreme Court affirmed the circuit court’s order confirming the award, holding (1) jurisdiction was properly under the Federal Arbitration Act; and (2) the circuit court did not err in failing to vacate the award on public policy grounds. View "Kilgore v. Mullenax" on Justia Law

Before the Supreme Court was Appellant’s sixth pro se petition requesting that the court reinvest jurisdiction in the trial court in his criminal case to consider a petition for writ of error coram nobis. Also before the court were several pro se motions filed by Appellant. The Supreme Court denied Appellant’s successive petition for coram nobis, denied Appellant’s pro se motions to supplement his successive petition, and declared moot the remaining motions, holding (1) Appellant failed to meet his burden of demonstrating meritorious grounds for the writ; and (2) the additional fact allegations contained in Appellant's pro se motion to supplement his successive petition failed to meet Appellant’s burden of demonstrating a fundamental error of fact extrinsic to the record. View "Jackson v. State" on Justia Law

Appellant was charged by information with three counts of rape, each involving a different occasion and a different victim. The offenses were severed for trial. Appellant was ultimately convicted on all three counts. In the instant habeas corpus petition, Appellant alleged, inter alia, that the trial court was without jurisdiction to impose two of the three sentences. The circuit court dismissed the petition. The Supreme Court affirmed the circuit court’s dismissal of Appellant’s pro se petition for writ of habeas corpus, holding that Appellant failed to allege a basis for the circuit court to grant the writ and demonstrated no clear error in the dismissal of his petition. View "Williams v. Kelley" on Justia Law

Appellant was convicted of capital murder, rape, kidnapping, and residential burglary. Appellant was sentenced to death for the capital murder conviction. The Supreme Court affirmed the judgment of the trial court, holding that the circuit court did not err by (1) denying Appellant’s motion for a directed verdict for the residential-burglary charge; (2) finding that Appellant’s offer to plead guilty to capital murder in exchange for a life sentence was not admissible as a mitigating factor showing Appellant’s acceptance of responsibility for his crimes; and (3) denying Appellant’s motion to suppress his custodial statement. View "Holly v. State" on Justia Law

Appellant, who was convicted of capital murder in 1995, filed a petition in 2016 seeking to compel the prosecuting attorney to direct the Arkansas State Crime Laboratory to turn over information from his case. The trial court denied the petition and counted the denial as a strike under Ark. Code Ann. 16-68-607. Thereafter, Appellant filed a motion for reconsideration. The trial court denied the motion for reconsideration, also finding that the new pleading merited a strike. The Supreme Court reversed in part, holding that the trial court erred in imposing the two strikes because section 16-68-607 does not confer authority on the trial court to impose a strike in a criminal case. View "Hill v. State" on Justia Law

Appellant, who was convicted of murder in the first degree with a firearm enhancement and attempted murder in the first degree, filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, asserting that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s trial counsel’s performance was not constitutionally deficient for any of the reasons stated by Appellant, as Appellant failed to establish prejudice under the standard set forth in Strickland v. Washington, 466 U.S. 668 (1984). View "Edwards v. State" on Justia Law

Statutory postjudgment interest on attorney’s fees accrues when the fees were actually quantified in dollars and cents rather than when the right thereto was first established.Plaintiff was granted judgment on her claim for retaliation under the Arkansas Whisteblower Protection Act. The circuit court entered judgment “plus costs and reasonable attorney’s fees to be determined by the court.” Three months later, the court entered a second order quantifying attorney’s fees. Defendant paid postjudgment interest on the attorney’s fees from the date that the award was entered. Plaintiff argued that she was entitled to attorney’s fees when the underlying judgment was entered. The circuit court granted the Department’s motion to compel entry of complete satisfaction. The Supreme Court affirmed, holding that postjudgment interest on an attorney’s-fee award accrues from the order setting the fee amount in dollars and cents. View "Daniel v. Arkansas Department of Human Services" on Justia Law

Petitioner pleaded guilty to ten counts of distribution, possession, or viewing of matter depicting sexually explicit conduct involving a child. Petitioner later filed a pro se notice of appeal. The court clerk declined to lodge the record because the notice of appeal was not timely. Petitioner subsequently filed a pro se motion for belated appeal and rule on clerk, alleging that he advised his counsel that he wished to appeal before the sentencing order was entered and that his notice of appeal was mailed to the circuit clerk in a timely fashion. The Supreme Court treated the motion for belated appeal and rule on clerk as a motion for belated appeal and granted the motion, holding that Petitioner was entitled to a direct appeal for the sentencing phase of his trial. View "Cox v. State" on Justia Law

Appellant was found guilty of murder in the first degree and sentenced to 480 months’ imprisonment. Approximately seventeen months after the judgment had been entered Appellant filed a pro se motion for a “nunc pro tunc order correcting and/or modifying the sentence,” arguing that he was entitled to have his sentence modified because the presumptive sentence for first-degree murder was 360 months’ imprisonment and because the trial court failed to issue written reasons for its departure from the presumptive sentence. The Supreme Court dismissed the appeal because Appellant’s motion to correct or modify his sentence was not timely filed. View "Beyard v. State" on Justia Law