Articles Posted in Arkansas Supreme Court

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The Supreme Court affirmed Defendant's convictions of two counts of premeditated and deliberate capital murder and sentencing him to life imprisonment without parole for each murder, holding that there was no prejudicial error in the proceedings below. Specifically, the Court held that the circuit court (1) did not abuse its discretion or deprive Appellant of his constitutional right to present a defense by excluding evidence that Appellant argued linked another person to the crimes; and (2) did not abuse its discretion in allowing testimony concerning what a person could see with a telescopic sight mounted on Appellant's rifle. View "Barefield v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition to proceed in forma paupers in a habeas proceeding, holding that the circuit court did not abuse its discretion in finding that Appellant should not be permitted to proceed at public expense. In denying the petition for writ of habeas corpus the circuit court found that the petition did not contain a colorable cause of action. The Supreme Court dismissed Appellant's appeal, which rendered moot Appellant's motion for extension of time to file his brief-in-chief, holding that Appellant's assertions and allegations were either not cognizable in habeas proceedings or brought without factual substantiation or development. View "Watson v. Kelley" on Justia Law

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The Supreme Court dismissed the State's appeal from the circuit court's decision to dismiss criminal charges against Defendant for violation of his speedy-trial rights, holding that Ark. R. App. P.-Crim. 3(d) prohibited this Court from considering the appeal. Defendant was arrested based on allegations that he had sexually assaulted his children. After the trial court granted the State six continuances Defendant filed a motion to dismiss for violation of his speedy-trial rights. The circuit court granted the motion. The State appealed, arguing that the case turned purely on an issue of law. The Supreme Court disagreed, holding that Rule 3(d) did not allow this Court to consider the State's appeal because the circuit court's decision to dismiss the charges turned upon the specific facts of this particular case. View "State v. Jones" on Justia Law

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The Supreme Court affirmed the circuit court's denial of Appellant's petition for postconvicton relief pursuant to Ark. R. Crim. P. 37, holding that the performance of Appellant's trial counsel was not deficient, and therefore, the circuit court's denial of Appellant's Rule 37 petition was not clearly erroneous. Appellant was convicted of one count of first-degree battery and one count of second-degree battery. After Appellant's convictions and sentences were affirmed on direct appeal, Appellant filed a petition for postconviction relief alleging that his trial counsel was ineffective in failing to investigate and call certain witnesses. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden under the first prong of Strickland v. Washington, 466 U.S. 668 (1984), because he did not demonstrate that his trial counsel's performance fell below an objective standard of reasonableness. View "Hinton v. State" on Justia Law

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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise a ground that was cognizable in coram nobis proceedings and failed to demonstrate that the writ should issue. Petitioner was convicted of aggravated robbery and first-degree battery and sentenced to 360 months' imprisonment. The court of appeals affirmed. In his petition for leave to reinvest jurisdiction for coram nobis proceedings, Petitioner challenged the sufficiency of the evidence supporting his conviction. The Supreme Court denied the petition, holding that that Petitioner's claims constituted a direct attack on the judgment and were not cognizable in a coram nobis proceeding. View "West v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the order of the circuit court denying Appellant's petition for writ of habeas corpus, holding that the circuit court's decision to deny Appellant's petition was not clearly erroneous. Appellant pleaded guilty to first-degree murder and was sentenced to 240 months' imprisonment. In his habeas petition, Appellant claimed that the writ should issue because his attorney gave him incorrect information concerning the laws governing speedy trial requirements and misled him about the expected testimony of a witness. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal, which mooted the motions filed in connection with the appeal, holding that Appellant's claims were not cognizable in habeas corpus proceedings. View "Bell v. Gibson" on Justia Law

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The Supreme Court affirmed the trial court's denial of Appellant's request for postconviction relief under Ark. R. Crim. P. 37.1, holding that the Rule 37.1 petition failed to raise a meritorious claim. Appellant was convicted of capital murder and other charges and sentenced to life imprisonment without parole for the murder charge plus a consecutive term of years for the remaining charges. Appellant filed a pro se petition for postconviction relief, alleging ineffective assistance of counsel on three bases. The trial court summarily denied the petition. The Supreme Court affirmed, holding that Appellant failed to show clear error in the summary denial of postconviction relief by the trial court. View "Williams v. State" on Justia Law

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The Supreme Court affirmed an order of the circuit court dismissing Appellant's petition to correct an illegal sentence, holding that the circuit court did not err in dismissing the petition. In 2013, Appellant was found guilty of capital murder, felon in possession of a firearm, unauthorized use of a vehicle, and abuse of a corpse. In Thornton I, the Supreme Court reversed and dismissed, holding that the evidence could not sustain the charge of capital murder. After the Court issued its mandate, the State filed a motion for the circuit court to consider lesser-included offenses. The circuit court granted the motion and ruled that the evidence from the 2013 bench trial was sufficient to find Appellant guilty of first-degree murder. The court then entered an amended sentencing order. Appellant filed a petition to correct an illegal sentence, claiming that, by reversing and dismissing his conviction in Thornton I, the Supreme Court reversed and dismissed all of his convictions. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the mandate in Thornton I did not reverse and dismiss Appellant's convictions for felon in possession of a firearm and abuse of a corpse. View "Thornton v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the circuit court's denial and dismissal of his pro se petition for reduction of sentence pursuant to Ark. Code Ann. 16-90-111, holding that there was no merit to the appeal. Appellant entered a guilty plea to rape and was sentenced to a term of 240 months' imprisonment. Appellant later filed his petition for reduction of the sentence, arguing that reduction was warranted because he had caused no trouble while incarcerated, he had already served a sufficient term, and he had served in the military and attended college prior to his incarceration. Appellant also filed a motion asking that counsel be appointed to represent him on appeal. The Supreme Court dismissed the appeal, which rendered moot the motion, holding that Appellant's assertions were not within the purview of the statute. View "Byrne v. State" on Justia Law

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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate a violation of Brady v. Maryland, 373 U.S. 83 (1963) or to otherwise establish a basis for coram nobis relief. Petitioner was convicted of second-degree battery, aggravated robbery, and other offenses. After Petitioner unsucessfully filed his coram nobis petition, he appealed. The Supreme Court affirmed, holding (1) the majority of Petitioner's coram nobis petition was made up of claims that the evidence adduced at trial was insufficient to prove his guilt, and such challenges to the sufficiency of the evidence are not cognizable in a coram nobis proceeding; and (2) Petitioner's one cognizable coram nobis claim alleging a Brady violation was made without any factual support and could not be a ground for the writ. View "Harrell v. State" on Justia Law