Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the trial court's denial of Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying relief.Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In this habeas petition, Appellant alleged that the arrest warrant was invalid, the trial court lacked the authority to amend the information, and the sentencing order was void. The circuit court dismissed the habeas corpus petition on the merits. The Supreme Court affirmed, holding (1) because Appellant's first two claims had been raised and rejected before and Appellant failed to bring new facts to enliven the claims, that failure constituted an abuse of the writ; and (2) the arguments Appellant made in support of his third argument lacked merit. View "Watson v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and possession of a firearm by certain persons and sentencing him to life imprisonment, holding that the circuit court did not err in finding that Appellant was fit to proceed to trial.After he was charged with first-degree murder and possession of a firearm Defendant moved for a competency determination. The circuit court found Defendant was not fit to proceed and committed him to the custody of the Arkansas State Hospital until he was restored to fitness. After Defendant underwent restoration proceedings the circuit court again held a hearing and found that Defendant was fit to proceed to trial. A jury subsequently found Defendant guilty. The Supreme Court affirmed, holding that the circuit court did not err in determining that Defendant was fit to stand trial. View "Hampton v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant's claim was not cognizable in a writ of habeas corpus.Appellant pleaded nolo contendere to multiple felony counts in three separate criminal cases. Appellant later filed a pro se petition for habeas corpus alleging that the sentences in these cases were illegal because the circuit court imposed a habitual-offender enhancement without proof that Appellant had committed more than one but less that four prior felonies. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was not within the purview of the habeas corpus remedy. View "Trammel v. Kelley" on Justia Law

The Supreme Court affirmed Appellant's conviction of rape and second-degree sexual assault and sentence of life imprisonment and twenty years' imprisonment, respectively, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported the jury's conclusion that Appellant committed rape; (2) the circuit court did not abuse its discretion by not instructing the jury on the offense of attempted rape; and (3) the circuit court did not abuse its discretion by allowing a witness to testify at sentencing about child-abuse statistics. View "Caple v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second 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 petition, Petitioner asserted that the prosecution withheld material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and withheld facts regarding information obtained during the police investigation. Petitioner later filed a motion asserting additional bases for issuance of the writ. The Supreme Court denied the petition and the motion, holding that Petitioner did not state sufficient allegations to satisfy issuance of the writ. View "Jones v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion for an independent action to set aside his conviction for fraud, holding that the trial court did not err in denying the motion on the basis that Defendant was precluded from seeking postconviction relief under Ark. R. Civ. P. 60(k).Defendant pleaded guilty to first-degree murder and was sentenced to life imprisonment. Defendant later filed a Rule 60(k) motion for an independent action to set aside his judgment for fraud upon the court, alleging that he did not agree to plead guilty in exchange for a life sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Rule 60 does not apply to criminal proceedings such as this one. View "Robinson v. State" on Justia Law

The Supreme Court granted Petitioner's pro se motion for rule on clerk and denied Petitioner's pro se motion for transcript, petition for writ of mandamus, and motion for appointment of counsel, holding that Petitioner was entitled to relief pursuant to Rule 2-2 of the rules of the Supreme Court.Petitioner was convicted of rape, aggravated residential burglary, and other crimes. In his motion for rule on clerk, Petitioner alleged that his counsel failed to perfect an appeal from his convictions by neglecting to lodge the record. The Supreme Court agreed, holding (1) because there was no order dismissing the appeal or otherwise relieving counsel from their obligation to perfect the appeal, counsel for Petitioner were obligated to lodge the record in the appellate court and to continue representing Petitioner; (2) because Petitioner's remedy lay in his motion for rule in clerk, his writ of mandamus is denied; and (3) Petitioner's motions either did not comply with the criminal rules of appellate procedure or were premature. View "Dominique v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by the Arkansas Secretary of State Appellant's complaint seeking to strike two proposed constitutional amendments, Issue 2 and Issue 3, from the general election ballot on November 3, 2020, holding that the circuit court did not err.On appeal, Appellant argued that the circuit court erred in ruling that the ballot titles were sufficient and that Issue 3 did not violate Ark. Const. art. XIX, 22. The Supreme Court affirmed, holding (1) article 19, section 22 governs the ballot titles of Issue 2 and Issue 3; (2) the circuit court properly ruled that Issue 2 and Issue 3 comply with the requirements of article 19, section 22; and (3) the circuit court did not err in ruling that Issue 3 did not violate article 19, section 22. View "Steele v. Thurston" on Justia Law

The Supreme Court affirmed the circuit court's denial of Stay Strong, Status Quo's appeal of a certified election petition, holding that there was no error on the part of the circuit court.In this election petition, Stay Strong, Status Quo, a local-option ballot-question committee, and Bevans Family Limited Partnership (together, Stay Strong) opposed Van Buren County Clerk Pam Bradford's certification of a local-option petition sponsored by Local Option Ballot Question Committee Let Van Buren County Vote (Sponsor). The circuit court dismissed the certification appeal without holding a hearing. The Supreme Court affirmed, holding (1) the circuit court did not err by dismissing the appeal without first taking evidence or holding a hearing; (2) the circuit court did not err by concluding that the petition form was valid; (3) the circuit court did not err in finding that there were sufficient signatures for certification; and (4) Stay Strong's argument for reversal based on the timing of its statutory appeal was unavailing. View "Stay Strong, Status Quo v. Bradford" on Justia Law

The Supreme Court denied Petitioner's pro se petition for writ of habeas corpus, motion to recall mandate to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis, and joinder of claims, holding that Petitioner's claims did not establish grounds for the relief he sought.Petitioner was convicted of rape and terroristic threatening. The Supreme Court denied Petitioner's petition and motions, holding (1) Petitioner must first file his habeas corpus petition in the circuit court in the county where he was incarcerated; and (2) Petitioner did not satisfy any ground for granting a writ of coram nobis because he did not allege that there was any evidence extrinsic to the record that was hidden from the defense or that was unknown at the time of trial. View "Mitchael v. State" on Justia Law