Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant's appeal from an order denying his pro se petition for permission to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that the circuit court had no jurisdiction to consider the petition.Appellant entered negotiated guilty pleas to rape and other offenses. Appellant later filed a petition for writ of error coram nobis in the Chicot County Circuit Court, the court where he was incarcerated, setting out two grounds for coram nobis relief. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that jurisdiction lay in the trial court where Appellant was convicted, which in this case was the Ashley County Circuit Court. Therefore, the Chicot County Circuit Court was without jurisdiction to address Appellant's coram nobis petition. View "Ray v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for declaratory judgment, holding that Appellant could not use a declaratory-judgment action to collaterally attack his criminal conviction.Appellant was convicted of first-degree murder and second-degree unlawful discharge of a firearm from a vehicle. The court of appeals affirmed. Years later, Appellant filed a petition for declaratory judgment alleging that he was denied due process in his criminal trial when the court admitted the prior testimony of an unavailable witness and that this admission violated the Confrontation Clause. The circuit court denied the petition. The Supreme Court affirmed, holding that a declaratory judgment action provided no relief on these grounds. View "Walker v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's "motion for credit for time spent in custody," holding that the circuit court's findings were not clearly erroneous.In his motion, Appellant alleged that he was entitled to 312 days of jail-time credit and that the circuit court should enter a new sentencing order nunc pro tunc that reflected the correct amount of jail-time credit. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court's denial of Appellant's motion was not clearly erroneous because Appellant failed to demonstrate a clerical error subject to correction. View "Barnett v. State" 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.Appellant was convicted of aggravated robbery, theft of property, and second-degree battery and sentenced as a habitual offender to an aggregate term of 660 months' imprisonment. The court of appeals affirmed. Appellant later petitioned for writ of habeas corpus, asserting that the trial court misapplied Arkansas's habitual-offender statutes. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the issues Appellant raised in his petition for the writ should have been raised at trial, on direct appeal, or in a petition for postconviction relief. View "Mason v. Kelley" on Justia Law

The Supreme Court affirmed Appellant's conviction of two counts of aggravated robbery, one count of theft of property, and one count of possession of a firearm by certain persons, holding that substantial evidence supported one of the aggravated robbery counts and that the circuit court did not err when it denied Appellant's motions to dismiss for speedy trial violations.On appeal, Appellant argued, among other things, that the circuit court erred when it denied his directed verdict motion with respect to one of the aggravated robbery counts. The Supreme Court affirmed, holding (1) substantial evidence supported the aggravated robbery conviction; and (2) Appellant's motions to dismiss for speedy trial violations were properly denied. View "McCray v. State" on Justia Law

The Supreme Court denied Petitioner's motion asking the Court to proceed with a belated appeal of a judgment reflecting his conviction on drug-related charges, holding that the trial court did not err in finding that Petitioner waived his right to appeal and that trial counsel had performed within an objectively reasonable standard.As grounds for the motion, Petitioner asserted that he asked counsel to appeal. The matter was remanded for a hearing. The trial court ultimately concluded that Petitioner waived his right to appeal and that counsel acted within an objective standard of reasonableness in not pursuing an appeal. The Supreme Court affirmed, holding that the trial court's conclusions were supported by the transcript and were not clearly erroneous. View "Smith 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 pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of first-degree murder and sentenced as a habitual offender to life imprisonment. More than thirty years later, Appellant filed his petition for writ of habeas corpus alleging that the judgment was void and the circuit court was without jurisdiction because the felony information charging him with the offense was not signed by the prosecuting attorney but, rather, was signed by a deputy prosecuting attorney on behalf of the prosecutor. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant did not state a basis for the writ. View "Davis v. Straughn" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the performance of Appellant's trial counsel was not deficient.Appellant was convicted of capital murder and sentenced to death. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5 alleging, among other claims, that trial counsel was ineffective concerning the mitigating circumstances presented to the jury and the failure to call any witnesses but his sister at the sentencing phase. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant's claim that he received ineffective assistance of counsel during the sentencing phase. View "Johnson v. State" on Justia Law

The Supreme Court denied Petitioner's second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and second petition for writ of certiorari, holding that Petitioner was not entitled to either coram nobis relief or issuance of a writ of certiorari.In two separate trials, Petitioner was convicted of the rapes of two girls and the rape of a five-year-old child and burglary. Petitioner subsequently filed multiple petitions for psostconviction relief, including the instant petitions for coram nobis relief and seeking issuance of a writ of certiorari. The Supreme Court denied coram nobis relief, holding (1) the claims raised in Petitioner's second coram nobis petition that reasserted claims raised in Petitioner's first coram nobis petition were an abuse of the writ; and (2) the remaining claims were either outside the scope on which the writ may issue or did not establish that Petitioner was entitled to coram nobis relief. The Court also denied Petitioner's petition for writ of certiorari, holding that the arguments in the petition could have been raised at trial or on direct appeal. The Court further denied Petitioner's motion for appointment of counsel as unwarranted and motion to withdraw as moot. View "Lukach v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's claims for postconviction relief raised under Ark. R. Crim. P. 37.1, holding that none of counsel's alleged errors created a reasonable probability of a different outcome had they not occurred.In denying postconviction relief, the trial court held that the alleged deficient actions of trial counsel were based on reasonable strategic and legal grounds and that counsel's alleged errors would not have changed the outcome of the trial. The Supreme Court affirmed, holding that to the extent trial counsel's performance arguably satisfied the first prong of Strickland, the failure did not satisfy the second prong - that Appellant's counsel's error was sufficiently prejudicial as to show a reasonable probability of a different outcome. View "Reynolds v. State" on Justia Law