Justia Arkansas Supreme Court Opinion Summaries
Hogan v. Payne
The Supreme Court affirmed the denial of Appellant's petition for writ of habeas corpus arguing that his sentence was illegal and that an amendment to the information was to vague to suffice as an amendment, holding that Appellant was not entitled to relief.After a jury trial, Appellant was convicted of possession of cocaine with intent to deliver. The jury sentenced Appellant as a habitual offender to a total of 125 years' imprisonment, and the court of appeals affirmed. Appellant later filed this petition for a writ of habeas corpus arguing that the State's oral amendment to the information was deficient. The circuit court denied the petition. The Supreme Court affirmed, holding that the trial court had authority to sentence Appellant as a habitual offender, and his sentence was within the range authorized under Ark. Code Ann. 5-4-501(b). View "Hogan v. Payne" on Justia Law
Posted in:
Criminal Law
Grady v. State
The Supreme Court affirmed Defendant's conviction of five counts of rape and his sentence to five concurrent terms of life imprisonment, holding that the circuit court did not abuse its discretion by denying Defendant's motion for a continuance.After a trial, Defendant was convicted of raping his minor stepson and sentenced to life imprisonment. On appeal, Defendant argued that the circuit court abused its discretion by denying a continuance to investigate a supplemental DNA report allegedly provided to the defense the Friday before trial. The Supreme Court rejected the argument and affirmed, holding that Defendant never requested a continuance to obtain an expert to perform DNA testing and that Defendant's argument was not preserved for appellate review. View "Grady v. State" on Justia Law
Posted in:
Criminal Law
White v. State
The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of life imprisonment, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) as to four of Defendant's allegations of error on appeal, five of them were not preserved; (2) the trial court did not abuse its discretion by rejecting Defendant's proffered justification instructions; (3) the trial court did not prevent Defendant from testifying about the victim's past violent acts; (4) Defendant was not entitled to resentencing based on the standard sentencing range for a Class Y felony; and (5) the trial court did not abuse its discretion by admitting two challenged photographs. View "White v. State" on Justia Law
Posted in:
Criminal Law
Chatmon v. Payne
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to demonstrate probable cause for issuance of the writ.Appellant was found guilty of three counts of aggravated robbery and one count of theft of property and sentenced to three life sentences. Appellant later filed a petition for writ of habeas corpus alleging that his convictions were invalid because the circuit judge who presided over his trial did not legally hold the position. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ. View "Chatmon v. Payne" on Justia Law
Posted in:
Criminal Law
Hunter v. Payne
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for a writ of habeas corpus and denied his motion to amend his reply brief, holding that there was no error.Appellant filed a petition for a writ of habeas corpus alleging that his sentence exceeded the maximum authorized by Ark. Code Ann. 5-64-422 and that the statute of limitations had expired on the primary offense underlying his engaging in a continuing criminal enterprise conviction. The Supreme Court affirmed, holding (1) Appellant's sentence was well within the statutory limits and was not illegal; and (2) the criminal information was timely filed for statute of limitations purposes. View "Hunter v. Payne" on Justia Law
Posted in:
Criminal Law
Stanton v. State
In this interlocutory appeal, the Supreme Court reversed the order of the circuit court disqualifying defense attorney Patrick Benca as Defendant's counsel in this criminal action, holding that the circuit court abused its discretion by disqualifying Benca from representing Defendant.Defendant was convicted of first-degree murder, but the convictions were reversed due to evidentiary error. Benca represented Defendant at his second trial. After a mistrial was declared due to Benca's becoming a witness during the second trial, the circuit court made clear that Benca was disqualified from participating as counsel for Defendant. Defendant was convicted after a third trial, at which he was represented by different attorneys. The conviction was reversed due to prosecutorial misconduct. Defendant retained Benca to represented him at his fourth trial, but the circuit court refused to recognize Benca as attorney of record based on the earlier order finding that Benca was disqualified. The Supreme Court reversed the order, holding that the circuit court abused its discretion by disqualifying Benca from representing Defendant. View "Stanton v. State" on Justia Law
Posted in:
Criminal Law
Dillon v. State
The Supreme Court affirmed the order of the circuit court denying Appellant's motion to withdraw his guilty, his petition to correct an illegal sentence imposed in an illegal manner, his petition to vacate and set aside or correct his sentence, and his motion for a new trial, holding that there was no clear error.In denying postconviction relief, the circuit court found that Appellant's multiple requests failed to meet the verification requirement of Ark. R. Crim. P. 37.1 and were otherwise untimely under Rule 37.2(c). The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied and dismissed Appellant's motions and petitions to withdraw his plea as unverified and to set aside his sentences as untimely. View "Dillon v. State" on Justia Law
Posted in:
Criminal Law
Lowery v. Payne
The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for a writ of habeas corpus filed in the county of his incarceration, holding that there were no grounds, stated in either the petition filed in the circuit court or in Appellant's arguments, on which a writ of habeas corpus could issue.On appeal, as he did below, Appellant argued that the trial court lacked jurisdiction to try and convict him by failing to adhere to Arkansas Supreme Court Administrative Order No. 5 and because he was not allowed to present certain evidence that would have exonerated him. The Supreme Court affirmed, holding there was no basis for finding that a writ of habeas corpus should issue. View "Lowery v. Payne" on Justia Law
Posted in:
Criminal Law
Crawford v. Payne
The Supreme Court affirmed the judgment of the circuit court concluding that Appellant, an inmate, had failed to state a ground for a writ of habeas corpus, holding that there was no error.Appellant brought a petition for writ of habeas corpus asserting that, in two separate cases involving multiple crimes, there was error in the charging and trial court process. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant's claims that he was never properly arraigned, appointed counsel, or served with an arrest warrant for the rape and kidnapping charges did not implicate the facility validity of the judgment or the trial court's jurisdiction, and therefore, the writ of habeas corpus should not be issued. View "Crawford v. Payne" on Justia Law
Posted in:
Criminal Law
Livingston v. Payne
The Supreme Court affirmed the dismissal of Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that the circuit court did not err in denying and dismissing the petition.In his petition, Appellant alleged that the original sentencing order was illegal because he had been charged as a habitual offender and was not entitled to probation and, therefore, the order revoking his probation and increasing his sentence was illegal. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied and dismissed Appellant's petition for the writ. View "Livingston v. Payne" on Justia Law
Posted in:
Criminal Law