Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to establish that the State violated Brady v. Maryland, 373 U.S. 83 (1963).Appellant was convicted of second-degree battery and being a felon in possession of a firearm and sentenced as a habitual offender to an aggregate term of 660 months' imprisonment. The court of appeals affirmed. In his petition for writ of error coram nobis Appellant alleged that the State committed a Brady violation by withholding the criminal history of two primary witnesses at his trial. The Supreme Court denied the petition, holding that Appellant failed to demonstrate the prejudice prong of a Brady claim. View "Russell v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his petition for writ of mandamus/prohibition, holding that Appellant filed his petition in the wrong county.A Phillips County jury convicted Appellant of sexual assault in he first degree. The court of appeals affirmed. Appellant later filed this petition in Phillips County for writ of mandamus/prohibition, alleging that Appellees miscalculated his parole eligibility by requiring that he serve 100 percent of his sentence pursuant to Ark. Code Ann. 16-93-609(b)(1). The circuit court denied the petition. The Supreme Court affirmed, holding that, where neither the director nor keeper of the records of the Arkansas Department of Correction was located in Phillips County, Appellant was not entitled to relief in the Phillips County Circuit Court. View "Jenkins v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for a writ of habeas corpus, holding that Appellant's claims fell outside the purview of habeas relief.Appellant was convicted of capital murder and kidnapping and sentenced to life imprisonment without parole. The Supreme Court affirmed on direct appeal. Appellant later filed a pro se petition for writ of habeas corpus, alleging that he was actually innocent and that insufficient evidence supported his capital murder conviction. The circuit court denied the petition for writ of habeas corpus. The Supreme Court affirmed, holding that where Appellant was not challenging the facial validity of his life sentence or the jurisdiction of the circuit court to enter the judgment of conviction, Appellant was not entitled to habeas relief. View "Peeler v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus, holding that the circuit court did not abuse its discretion in dismissing Appellant's petition.Appellant was convicted of rape and sentenced to two 120-month terms of imprisonment, to be served consecutively, for an aggregate term of 240 months' imprisonment. The court of appeals affirmed. Appellant later filed his petition for writ of habeas corpus, arguing that his consecutive sentences were illegal because the trial court abrogated the jury's recommendation for concurrent sentences. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's argument that the trial court lacked authority to impose consecutive sentences when the jury recommended concurrent sentences was without merit. View "Thompson v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellants was convicted of rape and fourth-degree sexual assault. The court of appeals affirmed the convictions and sentences. Appellant later brought this action raising five claims for habeas relief, including claims that he was tried in violation of his right to a speedy trial. The circuit court dismissed the habeas petition. The Supreme Court affirmed, holding that Appellant's claims fell outside the purview of habeas relief. View "Wade v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court resentencing Appellant to a term of life imprisonment, holding that the circuit court did not err in denying Appellant's resentencing motion, permanent-incorrigibility instruction, or witness testimony.Appellant was sixteen years old when he committed the crime that led to his conviction for capital murder. Appellant received a mandatory sentence of life imprisonment without the possibility of parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant's sentence was vacated. On remand, the circuit court resentenced Appellant to a sentence of life imprisonment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Appellant's "Motion to Determine the Appropriate Procedure and Sentencing Range for Resentencing"; (2) did not abuse its discretion in refusing Appellant's permanent-incorrigibility jury instruction; and (3) did not err in sustaining the State's objection to a witness's testimony comparing Appellant's rehabilitation to that of other inmates. View "Elliott v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's successive pro se petition requesting or obtaining an authorization order for leave to amend and supplement records pursuant to Act 1780, codified at Ark. Code Ann. 16-112-201 to -208, holding that Appellant was not entitled to relief.Appellant was found guilty of rape, kidnapping, robbery, and other offenses. In the instant petition, Appellant made three claims for relief, including a claim seeking testing of evidence from his criminal case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not rebut the presumption against timeliness, failed to state facts that would entitle him to scientific testing, and raised successive claims. View "Hooper v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for a writ of mandamus asking the Supreme Court to compel the circuit court to conduct a hearing on his petition for writ of habeas corpus filed under Ark. Code Ann. 16-112-201 to -208, holding that Petitioner failed to demonstrate that he was entitled to issuance of the writ.Petitioner pleaded guilty to first-degree murder and was sentenced to 240 months' imprisonment. Petitioner later filed a petition for writ of habeas corpus, arguing that the State withheld certain evidence held by the Arkansas State Crime Laboratory. Petitioner then brought this petition asking that the circuit court be compelled to conduct a hearing on his habeas petition. The Supreme Court denied the writ, noting that a hearing is not required on a habeas petition. View "Khalifa v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.In his coram nobis petition, Petitioner argued that there were clerical errors, mistakes in the process of notice and pleadings, and events outside the courtroom that affected the reliability of the proceedings. The circuit court denied the writ. The Supreme Court affirmed, holding that Petitioner's application for coram relief failed to offer any factual substantiation for his claims, and therefore, Petitioner was not entitled to the writ. View "Carroll v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant failed to establish that he was entitled to issuance of the writ.Appellant was convicted of battery in the first degree and battery in the second degree and was sentenced to an aggregate term of 264 months' imprisonment. Appellant later filed a petition for writ of habeas corpus alleging that the trial court did not have jurisdiction over his criminal case. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant's assertions did not implicate the facial validity of the trial court's judgment or its jurisdiction. View "Harkuf v. Kelley" on Justia Law