Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant’s interlocutory appeal from an order of the trial court that denied his pro se motion for reconsideration of the order that denied his motion to file an overlength amendment to his postconviction relief petition pursuant to Ark. R. Crim. P. 37.1, holding that the order that denied the motion for reconsideration was not a final, appealable order.In his Rule 37.1 petition, Appellant challenged the judgment of conviction entered in his criminal case and filed a motion seeking leave of the court to file an overlength amendment to the Rule 37.1 petition. After the trial court denied the motion, Appellant filed a motion for reconsideration, which was also denied. Appellant then filed this interlocutory appeal. The Supreme Court dismissed the appeal, holding that Petitioner was not permitted to proceed with an interlocutory appeal of the denial of motions filed in the course of a Rule 37.1 proceeding. View "Robinson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition for leave to proceed in forma pauperis in which he sought to proceed with a petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition because Appellant failed to raise a claim that can be recognized in a habeas proceeding.In denying the in forma pauperis petition, the circuit court found that Appellant had presented sufficient evidence to establish that he was indigent but failed to set forth a colorable cause of action. The Supreme Court affirmed, holding that Appellant’s claims of an involuntary plea or improper plea procedures were not properly addressed in a habeas proceeding. View "Mack v. Kelley" on Justia Law

The Supreme Court denied Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner was not entitled to relief.Petitioner, who was convicted of multiple counts of aggravated robbery, alleged in his petition that his sentence was illegally enhanced because the prosecutor withheld evidence supporting his habitual-offender status in violation of Brady v. Maryland, 373 U.S. 83 (1963). Petitioner also filed a pro se motion for sanctions to be placed upon the office of the attorney general. The Supreme Court denied the petition, holding that Petitioner failed to make sufficient allegations to warrant coram nobis relief and that coram nobis relief is not an available remedy for the purpose of seeking a reduction in a sentence. View "Bunch v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for writ of habeas corpus on the grounds that Appellant failed to establish that his sentence was facially illegal or that the trial court lacked jurisdiction, holding that Appellant failed to present any evidence establishing probable cause for issuance of the writ.Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant later filed a writ of habeas corpus alleging that he was being held pursuant to an invalid conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s claims were without merit and that Appellant was not entitled to a hearing. View "Grimes v. State" on Justia Law

The Supreme Court denied Petitioner’s pro se motion for belated appeal and rule on clerk seeking to proceed with a belated appeal of the judgment pursuant to Arkansas Rule of Appellate Procedure-Criminal 2(e), holding that the trial court did not err in finding that Petitioner did not articulate a his wish to file an appeal.Petitioner was convicted of sexual assault in the second degree. Petitioner later filed this motion arguing that his trial counsel failed to pursue a timely appeal on his behalf. The Supreme Court remanded the matter for an evidentiary hearing. On remand, after a hearing, the trial court found that Petitioner did not articulate a desire to appeal within the time limit allowed for counsel to file a timely notice of appeal. View "Beene v. State" on Justia Law

The Supreme Court reversed the order of the circuit court dismissing with prejudice this administrative appeal from final orders of the Arkansas Oil and Gas Commission (AOGC), holding that the circuit court erred in concluding that the doctrine of sovereign immunity barred its consideration of the petition for review of the AOGC orders.In addition to dismissing the administrative appeal, the circuit court declared the adjudicatory provisions of the Arkansas Administrative Procedure Act (APA) unconstitutional and declared the AOGC orders at issue void ab initio. The Supreme Court reversed the circuit court’s order in its entirety, holding (1) sovereign immunity was not implicated in this case because the role of the AOGC was that of a quasi-judicial forum and the AOGC was not “made defendant” within the meaning of Ark. Const. art. V, 20; and (2) because the circuit court erred in concluding that sovereign immunity applied to bar its consideration of the petition for review of the AOGC orders, the rulings declaring the adjudicatory provision of the APA unconstitutional and the AOGC’s orders void ab initio must also be reversed. View "Arkansas Oil & Gas Commission v. Hurd" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a sentence of life with parole eligibility pursuant to the Fair Sentencing of Minors Act of 2017 (the Act), holding that Appellant was entitled to resentencing in accordance with the Court’s decision in Harris v. State, 547 S.W.3d 64.In 1983, Appellant pled guilty to capital murder. Appellant was seventeen years old at the time of the murder and received a mandatory sentence of life without parole. Following the United States Supreme Court’s decision in Miller v. Alabama, 467 U.S. 460, 479 (2012), Appellant filed a petition for habeas corpus arguing that his sentence was unconstitutional. The circuit court granted the petition, vacated the sentence, and remanded Appellant’s case for resentencing. Although Appellant’s sentence had been vacated before the Act was enacted, the circuit court relied on the Act’s provision in resentencing him to life imprisonment with the possibility of parole after thirty years. The Supreme Court reversed, holding (1) based on this Court’s decision in Harris, the circuit court erred in applying the Act to Appellant’s case; and (2) Appellant was entitled to a hearing to present Miller evidence for consideration upon resentencing. View "Robinson v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s petition for a writ of habeas corpus, holding that Appellant’s arguments lacked merit.Appellant was convicted of first-degree murder and aggravated robbery and sentenced to life imprisonment for each conviction. In his petition for writ of habeas corpus, Appellant argued that Graham v. Florida, 560 U.S. 48 (2010), rendered his life sentence for aggravated robbery unconstitutional because he was a minor at the time of the offense and that Miller v. Alabama, 567 U.S.460 (2010, and Montgomery v. Louisiana, 136 S. Ct. 718 (2016) precluded his sentence even for his homicide offense. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant’s Miller-based argument was without merit; and (2) Graham had no application to Appellant’s case. View "Early v. Kelley" on Justia Law

The Supreme Court affirmed the denial of Appellant’s pro se petition for leave to proceed in forma pauperis on a petition for writ of habeas corpus, holding that it was clear from the record that Appellant’s cause of action could not proceed as a matter of law.The circuit court found that Appellant had presented sufficient evidence to establish that he was indigent but that he failed to allege a matter cognizable in a habeas petition and had not presented a colorable cause of action. The Supreme Court affirmed, holding that Appellant did not establish a basis for finding that a writ of habeas corpus should issue. View "Timmons v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court’s order dismissing Appellant’s counterclaim for declaratory and injunctive relief against the Arkansas Department of Human Services (DHS), holding that the Court was unable to address the sole issue raised by Appellant on appeal.On appeal, Appellant argued that the circuit court lacked jurisdiction to consider her counterclaim because DHS was entitled to sovereign immunity and that her case should be dismissed without prejudice due to lack of jurisdiction. The Supreme Court affirmed, holding that Appellant failed to preserve her sovereign-immunity argument, and therefore, the circuit court properly dismissed the counterclaim. View "Wilson v. Arkansas Department of Human Services" on Justia Law