Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise claims that are cognizable in coram nobis proceedings.Petitioner was found guilty of two counts of rape. In his coram nobis petition, Petitioner claimed that as a result of his mental defect he was incompetent to stand trial. The Supreme Court denied relief, holding that because Petitioner made no assertion that there was any evidence of his incompetence regarding a mental disease or defect extrinsic to the record, hidden from the defense, or unknown at the time of trial, Petitioner fell short of meeting his burden of disclosing a fact extrinsic to the record on which a writ of error coram nobis should issue. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of habeas corpus and petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err.Appellant, an inmate, pleaded guilty to failure to report and the related revocation in several felony cases. Appellant filed numerous pleadings, all of which the trial court denied. Appellant appealed the trial court's denial of habeas corpus and Rule 37.1 relief. The Supreme Court affirmed, holding (1) the circuit court lacked jurisdiction over Appellant's habeas corpus petition; and (2) because Appellant did not file his petition within the time limit set by Rule 37.1, the trial court properly denied postconviction relief. View "Taylor v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court convincing Defendant of first-degree murder and sentencing him to life imprisonment and a sentencing enhancement, holding that the circuit court did not err or abuse its discretion.A jury found Defendant guilty of the first-degree murder of Bianca Rainer. The Supreme Court affirmed the conviction, holding that the circuit court (1) did not err in refusing to suppress a detective's testimony about one of Defendant's custodial interviews that failed to record properly; and (2) did not abuse its discretion in admitting sixteen crime-scene and autopsy photographs of the victim over objections. View "Bennett v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellant was convicted of second-degree murder and sentenced to 300 months' imprisonment with a firearm enhancement of 180 months. In his habeas petition, Appellant alleged that the judgment of conviction did not reflect that his sentence was enhanced as a habitual offender by requiring him to serve 100 percent of his sentence, and therefore, his sentence was illegal. The circuit court denied the petition. The Supreme Court affirmed, holding that because the judgment may be corrected at any time to reflect that Appellant was not eligible for parole, Appellant failed to demonstrate that he was entitled to habeas relief on the basis that his enhanced sentence was illegal. View "Jones v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without the possibility of parole, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the conviction; (2) the circuit court did not err in admitting evidence regarding Defendant's prior bad acts under Ark. R. Crim. P. 404(b) because the evidence had independent relevance and was not unduly prejudicial; and (3) the circuit court did not err in not allowing Defendant to question a detective regarding a prior inconsistent statement made by a witness. View "Atwood v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant did not state a ground for the writ.Appellant was found guilty of first-degree murder and sentenced as a habitual offender to 600 months' imprisonment. Appellant later filed a petition for writ of habeas corpus, asserting that the judgment was void because the information was signed by a deputy prosecutor rather than the prosecuting attorney. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant did not establish a basis for the writ because Appellant's claim was not cognizable in habeas proceedings. View "Sims v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of rape, holding that there was no prejudicial error in the proceedings below.After a jury trial, Defendant was convicted of three counts of rape and sentenced to life imprisonment on each count. The Supreme Court affirmed, holding (1) the circuit court did not err when it did not grant Defendant's motion for a directed verdict; and (2) Defendant was not prejudiced and his right to a fair trial was not put in jeopardy when the circuit court allowed one of the victims to remain in the courtroom throughout the trial. View "Dominguez v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se motion to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that the motion was untimely.In 1990, Defendant was convicted of burglary and theft of property. Defendant was sentenced to forty years' imprisonment and thirty years' imprisonment, respectively. In his motion to correct an illegal sentence, Defendant argued that making the thirty-year sentence part consecutive and part concurrent was illegal. The trial court denied relief. The Supreme Court affirmed, holding (1) although Defendant characterized his claim as one alleging a facially invalid sentence, it was not, and therefore, section 16-90-111 did not apply; and (2) under Ark. R. Crim. P. 37.2(c), Defendant's motion was untimely. View "Prince v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's denial of Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that this Court lacked jurisdiction over the appeal.Appellant was convicted of capital murder and first-degree battery and sentenced to life imprisonment without parole. Appellant later filed a petition to correct an illegal sentence. The circuit court denied the petition, finding that it was untimely under Ark. R. Crim. P. 37.2. Appellant appealed. The Supreme Court affirmed, holding that Appellant did not proceed in the proper circuit court, and thus, the circuit court and the Supreme Court lacked jurisdiction to address his petition. View "Grant v. State" on Justia Law

The Supreme Court granted in part and dismissed in part an original action brought by Petitioners challenging the sufficiency of a state-wide petition to refer Act 579 of 2019 to the people of Arkansas on the November 3, 2020 general election ballot, holding that the petition was insufficient because it did not comply with Ark. Code Ann. 7-9-601(b)(3).Act 579 expanded the scope of the practice of optometry in Arkansas to permit licensed optometrists to perform certain procedures. Safe Surgery Arkansas (SSA), a ballot-question committee, filed with the Secretary its petition containing more than 84,000 signatures. The Secretary certified that the petition met constitutional signature requirements. Thereafter, Petitioners filed the instant original action alleging four counts regarding the insufficiency of the petition. The special master found that SSA lacked sufficient valid signatures to qualify the petition for the ballot. The Supreme Court granted in part and dismissed as moot in part the petition, holding (1) SSA's petition was insufficient because it failed to certify that its paid canvassers had passed criminal background checks; and (2) the remaining challenges to the petition were moot. View "Arkansans for Healthy Eyes v. Thurston" on Justia Law