Justia Criminal Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally. Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law

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The Supreme Court affirmed Appellant's convictions for capital murder and aggravated robbery, holding that none of Appellant's allegations of error warranted reversal. Specifically, the Court held (1) the State presented sufficient circumstantial evidence to support the convictions, and therefore, the circuit court did not err in denying Appellant's motion for directed verdict; (2) the circuit court did not abuse its discretion by denying Appellant's motion to exclude as hearsay testimony about the businesses Appellant called after the shooting; and (3) the circuit court did not err in denying Appellant's posttrial motion for mistrial because the jury's verdicts were consistent. View "Finley v. State" on Justia Law

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The Supreme Court reversed the decision of the circuit court dismissing for lack of jurisdiction Appellant's appeal from a district court judgment convicting him of driving while intoxicated and a speeding violation, holding that the circuit court erred in granting the State's motion to dismiss based not he circuit court's lack of jurisdiction. The circuit court dismissed Appellant's appeal of his conviction in district court as untimely pursuant to Ark. R. Crim. P. 36(c). On appeal, Appellant argued that the circuit court erred because the appeal was timely filed pursuant to Rule 36(d). The Supreme Court reversed, holding that the filing of Appellant's affidavit triggered jurisdiction of his appeal and strictly complied with Rule 36(d) to commence an appeal from the district court to the circuit court. View "Treat v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of rape and second-degree sexual assault, holding that the circuit court did not commit prejudicial error in allowing testimony from Defendant's daughter under the pedophile exception and allowing the State to inquire on cross-examination about a disputed police report. Specifically, the Court held (1) the circuit court did not abuse its discretion when it admitted the testimony of Defendant's daughter that Defendant sexually abused her when she was five or six years old; and (2) the circuit court erred by allowing the State to inquire on cross-examination about a disputed police report, but the error was harmless. View "Lowery v. State" on Justia Law

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The Supreme Court reversed Defendant's four convictions of negligent homicide, holding that the circuit court did not err by denying Defendant's motions for directed verdict. During trial, Defendant moved, unsuccessfully, for a directed verdict both at the close of the State's evidence and at the close of all the evidence. The Supreme Court reversed Defendants convictions and dismissed the case, holding that the circuit court erred in denying Defendant's motions for directed verdict. Specifically, the Court held that the State failed sufficiently to prove that Defendant should have been aware of a substantial risk that deaths would occur as a result of his conduct and that his conduct grossly deviated from the standard of care that a reasonable person would have exercised under the circumstances. View "Ledwell v. State" on Justia Law

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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner failed to show that he was entitled to the writ. In his petition, Petitioner argued that the State and his trial attorneys violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose certain statements by police officers and that there was an error during his trial. The Supreme Court denied the petition, holding that because the petition reasserted an allegation previously raised in this Court and an issue of trial error that is outside the scope of a coram-nobis proceeding, Petitioner was not entitled to coram-nobis relief. View "Hutcherson v. State" on Justia Law

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The Supreme Court affirmed the circuit court's dismissal of Appellant's pro se complaint alleging constitutional violations of his right to due process and constitutional violations of the ex post facto prohibition in connection with the denial of his application for parole, holding that Appellant's sole claim on appeal was abandoned. On appeal, Appellant argued for the first time that Appellees violated his right to equal protection because he had been treated differently from similarly situated inmates. The Supreme Court affirmed the circuit court's order dismissing Appellant's complaint, holding that because Appellant did not raise the argument below the issue could not be considered by this Court. View "Boydston v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court awarding attorney's fees to Allen Hargis following the division of Allen's military retirement account after the divorce of Allen and Lynn Harris, holding that the circuit court did not abuse its discretion by failing to conduct a hearing on the parties' respective financial abilities prior to awarding attorney's fees. After resolving the parties' dispute over the division of Allen's military retirement account following their divorce the circuit court awarded attorney's fees to Allen. On appeal, Lynn argued that the circuit court's failure to conduct a hearing prior to awarding attorney's fees infringed on her right to procedural due process under the Fourteenth Amendment. The Supreme Court affirmed, holding that the circuit court was not obligated to conduct an evidentiary hearing under the Fourteenth Amendment and that Lynn was not denied an opportunity to be heard on Allen's motion for attorney's fees. View "Hargis v. Hargis" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the circuit court's denial of his petition for writ of habeas corpus, holding that because Appellant was no longer incarcerated, the circuit court could not grant him the relief he requested. In his habeas petition, Petitioner challenged two judgments entered in 2008 and 2011. When he filed his habeas petition Petitioner was incarcerated in an Arkansas Department of Correction facility. By the time this case reached the Supreme Court Appellant was no longer incarcerated by the Arkansas Department of Correction. The Supreme Court dismissed Appellant's appeal from the denial of his petition, holding that the circuit court lacked jurisdiction to grant the requested relief. View "Green v. Kelley" on Justia Law

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The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow him to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner did not meet his burden of demonstrating a fundamental error of fact extrinsic to the record that was concealed from the defense and that was both material and prejudicial such as to have prevented rendition of the judgment had it been known at the time of trial. In his petition, Petitioner argued that the State withheld material evidence from the defense by failing to comply with pretrial discovery. The Supreme Court denied the petition, holding that Petitioner's conclusory allegations failed to demonstrate that the State concealed evidence or that Petitioner suffered prejudice sufficient to establish that a violation of Brady v. Maryland, 373 U.S. 83 (1963), occurred. View "Breeden v. State" on Justia Law