Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, holding that Petitioner failed to demonstrate in the petition that the writ should issue.In his petition, Petitioner argued that information was withheld in violation of Brady v. Maryland 373 U.S. 83 (1963), that the trial court lacked jurisdiction, and that there was no "bindover" at a preliminary hearing or grand jury. The Supreme Court denied the petition, holding (1) the majority of Petitioner's claims were an abuse of the writ; and (2) Petitioner's conclusory claims were not grounds for the writ. View "McClinton v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not err.In his petition, Petitioner argued that his sentence was illegal because the trial court lacked the authority to modify his sentence when it revoked his probation and that he was not afforded a preliminary hearing before he pled guilty to possession of a controlled substance. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the trial court had jurisdiction to modify Petitioner's sentence; and (2) Petitioner's remaining allegation constituted an untimely claim for postconviction relief. View "Ford v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that the trial court did not abuse its discretion in denying relief.Defendant pleaded guilty to three counts of first-degree assault, theft by receiving, and second-degree robbery. In his petition for a writ of error coram nobis Defendant argued that he was entitled to the writ pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied relief. The Supreme Court affirmed, holding that Defendant's multiple claims for error nobis relief failed because they were either conclusory, lacked supporting evidence, or did not fall within the purview of an error coram nobis proceeding. View "Everett v. State" on Justia Law

The Supreme Court dismissed on direct appeal the order of the circuit court denying in part Monsanto Company's motion for judgment on the pleadings and concluding that the Arkansas State Plant Board's Regulation 7 does not violate the Commerce Clause of the federal Constitution and is not invalid as being enacted by an unconstitutionally appointed board, holding that the circuit court did not err.The circuit court denied Monsanto's motion challenging the constitutionality of Regulation 7 and further granted judgment in favor of Monsanto on its claim that Ark. Code Ann. 2-16-206, the statute governing appointment of Board members, is an unconstitutional delegation of the appointment power. The Supreme Court dismissed on direct appeal and affirmed on cross-appeal, holding (1) the circuit court did not err in ruling that Regulation 7 does not violate the Commerce Clause or in rejecting Monsanto's argument that Regulation 7 was enacted by an unconstitutionally appointed board; and (2) the circuit court properly ruled that section 2-16-206(a)(5)-(13) is an invalid delegation of the appointment power. View "Monsanto Co. v. Arkansas State Plant Board" on Justia Law

The Supreme Court reversed the judgment of the circuit court finding that Ark. Code Ann. 2-16-206(a), which sets forth the appointment process for members of the Arkansas State Plant Board (ASPB), was constitutional, holding that the circuit court erred in ruling that the statute is constitutional.Appellant filed a complaint generally challenging the ASPB's dicamba cutoff rule and the denial of a petition for rule making submitted by Appellants and also sought a declaration that section 2-16-206(a) is unconstitutional. The circuit court concluded that the challenged rule was void ab initio and null and void as to Appellant. On remand from the Supreme Court the circuit court found that section 2-16-206(a) was constitutional. The Supreme Court reversed, holding that section 2-16-206(a) is unconstitutional. View "McCarty v. Arkansas State Plant Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that Appellant failed to allege that his sentence was facially illegal or that the trial court lacked subject matter jurisdiction.Appellant pleaded guilty to four counts of first-degree sexual assault and was sentenced to 336 months' imprisonment. Appellant later filed a petition to correct an illegal sentence, but none of Appellant's claims asserted that his sentence was facially illegal or that the circuit court lacked subject-matter jurisdiction. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied Appellant's petition to correct an illegal sentence. View "Hayes v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief under Ark. R. Crim. P. 37.1 without holding an evidentiary hearing, holding that the petition and record conclusively showed that Defendant was not entitled to relief.Defendant was convicted of raping his young daughter and sentenced as a habitual offender to life imprisonment without parole. Defendant later filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel and other claims for relief. The circuit court denied the petition, concluding that Defendant's claims were without merit. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the petition. View "Rayburn v. State" on Justia Law

The Supreme Court affirmed an order of the circuit court denying Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the circuit court abused its discretion in declining to grant the relief sought.In his petition for writ of error coram nobis Appellant alleged that the State withheld exculpatory evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). After a hearing, the circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Appellant's claims and denying his pro se petition for writ of error coram nobis. View "Myers v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant to life imprisonment after a resentencing hearing, holding that no prejudicial error occurred.Defendant, who was seventeen when he committed the offenses, was convicted of capital murder and aggravated robbery and sentenced to life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Defendant's sentence was vacated and a resentencing hearing was held. The trial court subsequently imposed a life sentence. The Supreme Court affirmed, holding that the trial court did not err or abuse its discretion. View "Ventry v. State" on Justia Law

The Supreme Court affirmed the decision 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 state a basis for issuance of the writ.Appellant was convicted of aggravated robbery and sentenced to life imprisonment as a habitual offender. Appellant later filed this petition for a writ of habeas corpus, arguing that the trial court's failure to hold a hearing regarding whether he should have been charged as an adult violated his due process rights and rendered his sentence invalid. The Supreme Court affirmed the circuit court's dismissal of the petition, holding that Appellant was not entitled to relief. View "Osborn v. Payne" on Justia Law