Justia Criminal Law Opinion Summaries

The Supreme Court treated Petitioner’s pro se motion for rule on clerk and for belated appeal as a motion for belated appeal and denied the motion, holding that Petitioner’s petition was wholly without merit.Petitioner sought to appeal the trial court’s denial of his pro se petition to correct an illegal sentence filed under Ark. Code Ann. 16-90-111. The trial court addressed the petition as one for postconviction relief under Ark. R. Crim. P. 37.1 and under Ark. Code Ann. 16-90-111 and then denied the petition. The Supreme Court affirmed, holding (1) the denial of Petitioner’s claim for relief under section 16-90-111 was not error; and (2) Petitioner was not entitled to relief under Rule 37.1. View "Latham v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of capital murder, thus rejecting Defendant’s arguments for reversal on appeal.After Defendant was convicted, Defendant was sentenced to life in prison without the possibility of parole. On appeal, Defendant argued that the trial court erred in admitting a confession he made while in custody and incorrectly declined to adopt his suggested modifications of, and omissions from, the submitted model jury instructions. The Supreme Court affirmed, holding (1) the trial court did not clearly err in refusing to suppress Defendant’s confession; and (2) the trial court did not abuse its discretion in declining Defendant’s proposed modifications of, and omissions from, the submitted model jury instructions. View "Kellon v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of capital murder, thus rejecting Defendant’s arguments for reversal on appeal.After Defendant was convicted, Defendant was sentenced to life in prison without the possibility of parole. On appeal, Defendant argued that the trial court erred in admitting a confession he made while in custody and incorrectly declined to adopt his suggested modifications of, and omissions from, the submitted model jury instructions. The Supreme Court affirmed, holding (1) the trial court did not clearly err in refusing to suppress Defendant’s confession; and (2) the trial court did not abuse its discretion in declining Defendant’s proposed modifications of, and omissions from, the submitted model jury instructions. View "Kellon v. State" on Justia Law

The Supreme Court treated Petitioner’s pro se “petition for review en banc of the clerks [sic] decision” as a motion for rule on clerk and dismissed the motion.Petitioner was convicted of eighteen counts of possession of child pornography. The court of appeals affirmed on appeal. Petitioner then filed a pro se petition under Ark. R. Crim. P. 37.1. The trial court dismissed the Rule 37.1 petition because the petition did not have the necessary affidavit under Rule 37.1(c). Petitioner filed a notice of appeal of the order, but the clerk declined to file the record because it was not timely tendered. Petitioner then filed this petition alleging that the procedural default should be excused. The Supreme Court dismissed the petition, holding that because the trial court did not have authority to consider the merits of the petition when it did or later, Petitioner could not succeed on appeal. View "Whitney v. State" on Justia Law

The Supreme Court treated Petitioner’s pro se “petition for review en banc of the clerks [sic] decision” as a motion for rule on clerk and dismissed the motion.Petitioner was convicted of eighteen counts of possession of child pornography. The court of appeals affirmed on appeal. Petitioner then filed a pro se petition under Ark. R. Crim. P. 37.1. The trial court dismissed the Rule 37.1 petition because the petition did not have the necessary affidavit under Rule 37.1(c). Petitioner filed a notice of appeal of the order, but the clerk declined to file the record because it was not timely tendered. Petitioner then filed this petition alleging that the procedural default should be excused. The Supreme Court dismissed the petition, holding that because the trial court did not have authority to consider the merits of the petition when it did or later, Petitioner could not succeed on appeal. View "Whitney v. State" on Justia Law

The Fourth Circuit affirmed the district court's application of a sentencing enhancement under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), holding that defendant's prior conviction under the North Carolina crime of voluntary manslaughter was a violent felony under the force clause of the ACCA. The court explained that voluntary manslaughter in North Carolina required an intentional killing, and thus plainly involved "the use, attempted use, or threatened use of physical force against the person of another." View "United States v. Smith" on Justia Law

The Fourth Circuit affirmed the district court's application of a sentencing enhancement under the Armed Career Criminal Act (ACCA), 18 U.S.C. 924(e), holding that defendant's prior conviction under the North Carolina crime of voluntary manslaughter was a violent felony under the force clause of the ACCA. The court explained that voluntary manslaughter in North Carolina required an intentional killing, and thus plainly involved "the use, attempted use, or threatened use of physical force against the person of another." View "United States v. Smith" on Justia Law

The lengthy delay between Defendant’s arrest in this case and his eventual guilty plea violated his constitutional right to a speedy trial.Defendant was charged in an indictment with murder in the second degree and other crimes. The time between Defendant’s arrest and his eventual guilty plea spanned six years, three months, and twenty-five days. Defendant spent the entirety of that period incarcerated. On appeal, the Appellate Division held that Defendant’s constitutional right to a speedy trial was not violated. The Court of Appeals reversed the order of the Appellate Division and dismissed the indictment, holding that, after evaluating all the relevant factors set forth in People v. Taranovich, 37 N.Y.2d 442 (1975), under the circumstances of this case, Defendant’s constitutional right to a speedy trial was violated. View "People v. Wiggins" on Justia Law

The lengthy delay between Defendant’s arrest in this case and his eventual guilty plea violated his constitutional right to a speedy trial.Defendant was charged in an indictment with murder in the second degree and other crimes. The time between Defendant’s arrest and his eventual guilty plea spanned six years, three months, and twenty-five days. Defendant spent the entirety of that period incarcerated. On appeal, the Appellate Division held that Defendant’s constitutional right to a speedy trial was not violated. The Court of Appeals reversed the order of the Appellate Division and dismissed the indictment, holding that, after evaluating all the relevant factors set forth in People v. Taranovich, 37 N.Y.2d 442 (1975), under the circumstances of this case, Defendant’s constitutional right to a speedy trial was violated. View "People v. Wiggins" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and conspiracy to commit murder and sentencing him to life imprisonment without parole for the murder conviction. The Supreme Court held (1) the State presented sufficient evidence to support Defendant’s convictions, and the court declined to reweigh the evidence; (2) the trial court did not commit reversible error in admitting certain evidence to which Defendant objected; and (3) Defendant’s life without parole sentence for murder was both constitutionally proportional and appropriate under Appellate Rule 7(B). View "McCallister v. State" on Justia Law