Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his motion for reconsideration of an order that set a partial filing fee of twenty dollars with respect to Appellant’s pro se civil complaint in tort against seven persons, holding that the circuit court did not err when it denied the motion for reconsideration.The circuit court denied Appellant’s request for reconsideration because it was not timely filed pursuant to Ark. R. Civ. P. 60(a). The Supreme Court affirmed, holding that because Appellant did not ask for reconsideration of the circuit court’s order until 155 days after the order had been entered, Appellant’s motion was untimely, and therefore, the circuit court did not err in denying it. View "Whitney v. Cruce" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for a writ of habeas corpus, holding that the circuit court did not err in dismissing the petition.Appellant was convicted for a string of robberies he committed when he was seventeen years old. In his habeas corpus petition, Appellant argued that the 240-year cumulative sentence he was serving was a de facto life sentence in violation of Graham v. Florida, 560 U.S. 48 (2010) and that he sentence was grossly disproportionate to his crimes. The circuit court denied the petition. The Supreme Court affirmed, holding (1) where Appellant had multiple sentences and no individual sentence was a life sentence, Graham did not apply; and (2) Appellant’s argument that his sentence was grossly disproportionate to the crimes he committed was not preserved for review. View "Proctor v. Kelley" on Justia Law

The Supreme Court remanded the instant appeal of the circuit court’s order denying Appellant’s pro se petition for leave to proceed in forma pauperis in which Appellant sought to proceed with a civil-rights complaint against certain Arkansas Department of Correction (ADC) employees, holding that the order was not sufficient for review, and therefore, the case must be remanded for findings of fact.The order at issue found that Appellant was not indigent and must pay the statutory filing fee for the action. The Supreme Court held (1) contrary to the assertion of Appellee, the director of the ADC, the order was appealable; and (2) the cause must be remanded for a supplemental order on the in forma pauperis petition that contains adequate findings of fact on the issue of whether Appellant was indigent. View "Berger v. Kelley" on Justia Law

The Supreme Court reversed Defendant’s conviction of possession of methamphetamine, holding that the circuit court erred by denying Defendant’s motion to suppress because the search of Defendant’s wallet violated the Fourth Amendment of the United States Constitution.Defendant was arrested and charged with possession of methamphetamine after the arresting officer discovered the drug in Defendant’s wallet. In his suppression motion, Defendant argued that the officer did not have a reasonable, articulable suspicion to search him for weapons and lacked probable cause or reasonable suspicion to search his wallet. The Supreme Court agreed, holding that the officer did not have probable cause to search Defendant’s wallet, and because Defendant did not consent to the search of his wallet, the search violated the Fourth Amendment. View "Shay v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant’s petition for writ of error coram nobis, holding that the circuit court did not err in dismissing the petition, limiting discovery for the evidentiary hearing, or denying Appellant’s motion for judicial recusal.Appellant was convicted of capital murder and sentenced to death. Appellant later petitioned the Supreme Court to reinvest jurisdiction in the circuit court to allow him to seek a writ of error coram nobis. The Supreme Court revinested the circuit court with jurisdiction to consider Appellant’s claims of Brady violations. After a hearing, the circuit court dismissed Appellant’s petition for writ of error coram nobis. The Supreme Court affirmed, holding (1) because Appellant failed to demonstrate Brady violations, the circuit court did not err in dismissing Appellant’s petition for writ of error coram nobis; (2) the circuit court did not abuse its discretion in limiting discovery; and (3) the circuit court did not abuse its discretion in denying Appellant’s motion for recusal. View "Isom v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se second petition to reinvest jurisdiction with the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate that the writ should issue and that several of Petitioner’s claims were successive.Petitioner was convicted of first-degree murder and sentenced as a habitual offender to 720 months’ imprisonment. In his second coram nobis petition, Petitioner claimed that he suffered a variety of defects in the underlying criminal proceedings, including a Brady violation. The Supreme Court denied relief, holding (1) where several of Petitioner’s claims were raised in his first coram nobis petition and were again raised here without additional facts, these arguments constituted an abuse of the writ; and (2) the one issue that Petitioner did not previously raise did not provide a basis for the issuance of this extraordinary writ. View "Smith v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the denial of the circuit court of his motion for reconsideration of an order that set a partial filing fee of twenty dollars with respect to Appellant’s pro se civil complaint in tort, holding that the circuit court did not err when it denied the motion for reconsideration.The circuit court denied Appellant’s request for reconsideration because it was not timely filed pursuant to Ark. R. Civ. P. 60(a). The Supreme Court affirmed, holding that because Appellant did not ask for reconsideration of the circuit court’s order until 155 days after the order had been entered, Appellant’s motion was untimely, and therefore, the circuit court did not err in denying it. View "Whitney v. Plummer" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his motion for reconsideration of an order that set a partial filing fee of thirty-five dollars with respect to his pro se petition for writ of mandamus, holding that the circuit court did not err when it denied the motion for reconsideration.The circuit court denied Appellant’s request for reconsideration because it was not timely filed pursuant to Ark. R. Civ. P. 60(a). Because Appellant did not ask for reconsideration of the circuit court’s order until 197 days after the order had been entered the Supreme Court affirmed, holding that Appellant’s motion for reconsideration was untimely. View "Whitney v. Hutchinson" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court denying his motion for reconsideration of an order that set a partial filing fee of twenty dollars with respect to Appellant’s pro se civil complaint in tort, holding that the circuit court did not err when it denied Appellant’s motion for reconsideration.The circuit court denied Appellant’s request for reconsideration because it was not timely filed pursuant to Ark. R. Civ. P. 60(a). Appellant did not ask for reconsideration until 155 days after the ordered had been entered. The Supreme Court held that the circuit court did not err in denying Appellant’s motion because it was untimely. View "Whitney v. Allen, Boreani, Ross, Watson & Payne" on Justia Law

The Supreme Court denied Petitioner’s petition to reinvest jurisdiction in the trial court so that he may file a petition for writ of error coram nobis in his criminal case, holding that Petitioner did not state a ground for the writ.In his petition, Appellant argued that the trial court and court of appeals made errors that amounted to a breakdown in both the trial and the direct-appeal proceedings and that the evidence was insufficient to sustain the judgment. The Supreme Court denied relief, holding that error by the trial court or the appellate court is not a ground to grant a writ of error coram nobis and that an attack on the sufficiency of the evidence is not within the purview of a coram nobis proceeding. View "Hall v. State" on Justia Law