Articles Posted in Arkansas Supreme Court

by
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the petition. Appellant pled guilty to one count of rape. In his coram nobis petition, Appellant alleged, among other things, that the guilty plea was coerced. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding (1) certain exhibits Appellant included in his brief to support his claim on appeal that were not included in Appellant's petition to the circuit court or otherwise contained in the record are removed from consideration; and (2) under the circumstances, the circuit court did not abuse its discretion in denying Appellant's petition. View "Kain v. State" on Justia Law

by
The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of habeas corpus, holding that none of Appellant's claims were sufficient to demonstrate that the trial court lacked jurisdiction or that the judgment of conviction was invalid on its face. In 1991, Appellant was found guilty of capital murder and was sentenced to life imprisonment without parole. In 2018, Appellant filed his petition for a writ of habeas corpus, arguing, among other things, that new evidence had emerged exonerating him of the crime and that material evidence was withheld at his trial in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court found that the habeas petition was untimely and without merit. The Supreme Court affirmed, holding that Appellant failed to make a showing that the face of the judgment was invalid or to present evidence of probable cause to believe he was being illegally detained. View "McArthur v. State" on Justia Law

by
The Supreme Court dismissed Appellant's appeal from the order of the circuit court dismissing his pro se petition for a writ of habeas corpus, which rendered his motions filed in connection with the appeal moot, holding that Appellant failed to demonstrate that the sentence was illegal on its face or the trial court lacked jurisdiction. Appellant pleaded guilty to attempted first-degree murder and first-degree battery and was sentenced to 540 months' imprisonment. In his habeas petition, Appellant argued that the trial court failed to pronounce sentence in open court at the conclusion of the plea hearing in violation of Ark. Code Ann. 16-90-106(d). The circuit court denied postconviction relief. The Supreme Court affirmed, holding that Appellant's sentences were not illegal on the face of the judgment, and there was no showing that the trial court lacked jursidiction to impose the sentences. View "Johnson v. Kelley" on Justia Law

by
The Supreme Court denied Petitioner's motion for permission to proceed with a belated appeal of an order denying his pro se petition for writ of error coram nobis, which mooted his additional motions, holding that the circuit court did not abuse its discretion in denying relief. In addition to his motion for belated appeal Petitioner filed motions for appointment of counsel, to supplement appeal, to file rule on clerk, to add "to [his] error coram nobis," second motion to supplement, and second motion to add. In his coram nobis petition Petitioner asserted that his allegations of mental disease or defect were not fully adjudicated, that his guilty plea was coerced, and that his trial counsel was ineffective. The circuit court denied the petition. The Supreme Court held that Petitioner's ineffective assistance of counsel claim was not a ground for the writ and that the two other claims failed to allege any facts to support those claims. Therefore, the Court held, the coram nobis petition was wholly without merit, and Petitioner could show no abuse of discretion in the denial of relief and could not prevail on appeal. View "Bryant v. State" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's petition for habeas relief, holding that the circuit court did not clearly err when it denied the petition. As grounds for his petition, Appellant argued that his arrest was invalid because an arrest warrant did not issue, the criminal information was filed without supporting documentation, and the introduction of any evidence was illegal according to the fruit of the poisonous tree doctrine. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate error in the dismissal of his petition because he failed to allege a basis for the circuit court to grant the writ. View "Mister v. Kelley" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying Appellant leave to proceed in forma pauperis on his petition for writ of habeas corpus, holding that the underlying habeas petition set out a claim that fell within those cognizable for the writ, yet it did not provide an adequate demonstration of probable cause to support issuance of the writ. Appellant was convicted of rape and first-degree sexual assault entered on a negotiated guilty plea and was sentenced to sixty years' imprisonment. Appellant filed a petition for writ of habeas corpus alleging that the trial court did not have the authority to enter the judgment because he did not in fact enter a guilty plea. Appellant then filed his petition for leave to proceed in forma pauperis. The circuit court denied relief, finding sufficient evidence that Appellant was indigent but that he failed to allege a matter cognizable in a petition for the writ. The Supreme Court affirmed, holding that the claims in Appellant's habeas petition were not sufficient to support his allegations of a colorable cause of action. View "Morgan v. Kelley" on Justia Law

by
The Supreme Court affirmed the decision of the circuit court denying Appellant's request to proceed in forma paupers on a petition for writ of habeas corpus, holding that Appellant failed to state a colorable cause of action for habeas relief. Appellant was convicted of drug-related crimes. Appellant was later convicted of additional felony offenses and sentenced as a habitual offender to life imprisonment. In the instant habeas petition, Appellant raised the same claims and factual allegations for habeas relief that he had raised previously in a habeas petition and that were rejected by this Court. The circuit court concluded that Appellant failed to state a colorable claim for habeas relief because the same claims had been previously addressed and found to be outside the purview of habeas proceedings. The Supreme Court affirmed, holding that the circuit court did not err. View "Watts v. Kelley" on Justia Law

by
The Supreme Court dismissed Appellant's appeal from the circuit court's denial of his pro se petition to correct an illegal sentence, which mooted Appellant's motion for an extension of time to file his brief-in-chief, holding that that Appellant's sentence of life imprisonment was illegal. Appellant was convicted of capital murder and aggravated robbery and was sentenced to life imprisonment. In his petition to correct an illegal sentence Appellant alleged that his mandatory sentence of life imprisonment should be set aside pursuant to Miller v. Alabama, 567 U.S. 460, and Graham v. Florida, 560 U.S. 48 (2010), because he was eighteen when he committed the crimes. The circuit court denied relief. The Supreme Court dismissed the appeal, which rendered Appellant's motion moot, holding that because Appellant was an adult when he committed capital murder, his sentence of life imprisonment was not illegal. View "Burgie v. State" on Justia Law

by
The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that it was clear from the face of the petition that Appellant did not substantiate with facts a ground for relief in his Rule 37.1 petition. In his petition, Appellant alleged four of his claims of ineffective assistance of counsel. The trial court denied the petition. Appellant appealed and filed a motion for an extension of time to file a reply brief in the appeal. The Supreme Court (1) affirmed the denial of Appellant's postconviction petition, holding that Appellant failed to support the four allegations that he argued on appeal were wrongfully decided by the trial court with facts to demonstrate that he suffered actual prejudice by any of counsel's alleged errors; and (2) denied the motion for extension of brief time, holding that there was no good cause to delay action on the appeal by granting leave to file a reply brief. View "Maiden v. State" on Justia Law

by
The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition for a writ of error coram nobis, which mooted Appellant's motion to file a belated brief-in-chief, holding that it was clear from the record that Appellant's allegations failed state a claim for coram nobis relief. In his petition, Appellant asserted that his guilty plea was not voluntarily or intelligently entered because his counsel led him to believe that his sentence would be life imprisonment, not life imprisonment without the possibility of parole. The Supreme Court dismissed the appeal, holding that Appellant did not allege that his guilty plea resulted from any form of physical or psychological duress as required for a writ of error coram nobis in this context. View "Wade v. State" on Justia Law