Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for writ of habeas corpus seeking scientific testing of evidence from his criminal case, holding that Appellant failed to establish the timeliness of the petition or its merit.Appellant was found guilty in 1994 of capital murder with the underlying offenses of kidnapping and rape and was sentenced to life imprisonment without parole. In 2019, Appellant filed the instant petition for scientific testing of evidence pursuant to Ark. Code Ann. 16-112-201 to -208. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant did not establish by clear and convincing evidence that no reasonable fact-finder would find him guilty of the murder of the victim based on any specific testing; (2) Appellant did not satisfy any of the factors that would establish that his petition was timely; and (3) the trial court was not obligated to hold a hearing on the petition. View "Mills v. State" on Justia Law

The Supreme Court reversed the ruling of the circuit court denying the motion filed by Asa Hutchinson, the Governor of the State of Arkansas, to dismiss an action filed by Appellee, an inmate in the Arkansas Department of Correction, holding that the complaint was barred by sovereign immunity.Appellee filed a complaint challenging the constitutionality of the Fair Sentencing of Minors Act of 2017 (FSMA), codified at Ark. Code Ann. 16-93-621, alleging that the FSMA denied him equal protection and due process of law, subjected him to cruel and unusual punishments, and violated the Americans with Disabilities Act. The circuit court dismissed the action with respect to all defendants except Hutchinson in his official capacity. The Supreme Court reversed, holding that the circuit court erred in ruling that Appellee pleaded sufficient facts to overcome Hutchinson's defense of sovereign immunity. View "Hutchison v. Mcarty" on Justia Law

In a certified question of law regarding the requirement for creditors to comply strictly with the Arkansas Statutory Foreclosure Act the Supreme Court held that Ark. Code Ann. 18-50-104(b)(4) requires disclosure of the specific default under the terms of the mortgage agreement.The Court by the United States Bankruptcy Court for the Western District of Arkansas certified the question of law to the Supreme Court, asking whether mere acknowledgment that a default has occurred is sufficient for the trustee's Notice of Default and Intention to Sell or whether section 18-5-104(b)(4) requires the trustee's notice of default to set forth the default for which foreclosure is made. The Supreme Court answered that the statute requires that the notice must state the specific default that occurred. View "Davis v. Pennymac Loan Services, LLC" on Justia Law

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