Justia Criminal Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.Appellant was convicted of four counts of computer exploitation of a child in the first degree and twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. Appellant later filed a petition for a writ of corpus alleging that his convictions were invalid for several reasons. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish that the circuit court erred by denying habeas relief. View "Rea v. Kelley" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that none of Appellant's allegations were cognizable in a habeas proceeding.Appellant entered a guilty plea to three counts of first-degree terroristic threatening and was sentenced to 120 months in prison. In his habeas petition, Appellant argued that there was insufficient evidence to support the convictions, his arrest was illegal, and his guilty plea was rendered involuntary by flaws in the plea proceedings. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's habeas claim was properly denied. View "Lewis v. Payne" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to grant the relief sought.In two separate criminal cases, Appellant pled guilty to multiple charges of commercial burglary. In his coram nobis petition, Appellant argued that his guilty plea was coerced when two police officers threatened to charge his wife. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant's claim of coercion was unsubstantiated and that, even if it were substantiated, Appellant failed to pursue the claim with diligence. View "Lewis v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed in the county where Appellant was incarcerated pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of aggravated robbery, first-degree battery, and attempted rape and was sentenced as a habitual offender. In his habeas corpus petition, Appellant asserted that he was deprived of his right to an appeal due to his counsel's procedural error, that his conviction for attempted rape was not supported by sufficient evidence, and that his parole eligibility date was miscalculated. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. View "Hall v. State" on Justia Law

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The Supreme Court affirmed the trial court's denial of Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying relief.Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In this habeas petition, Appellant alleged that the arrest warrant was invalid, the trial court lacked the authority to amend the information, and the sentencing order was void. The circuit court dismissed the habeas corpus petition on the merits. The Supreme Court affirmed, holding (1) because Appellant's first two claims had been raised and rejected before and Appellant failed to bring new facts to enliven the claims, that failure constituted an abuse of the writ; and (2) the arguments Appellant made in support of his third argument lacked merit. View "Watson v. Payne" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and possession of a firearm by certain persons and sentencing him to life imprisonment, holding that the circuit court did not err in finding that Appellant was fit to proceed to trial.After he was charged with first-degree murder and possession of a firearm Defendant moved for a competency determination. The circuit court found Defendant was not fit to proceed and committed him to the custody of the Arkansas State Hospital until he was restored to fitness. After Defendant underwent restoration proceedings the circuit court again held a hearing and found that Defendant was fit to proceed to trial. A jury subsequently found Defendant guilty. The Supreme Court affirmed, holding that the circuit court did not err in determining that Defendant was fit to stand trial. View "Hampton v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant's claim was not cognizable in a writ of habeas corpus.Appellant pleaded nolo contendere to multiple felony counts in three separate criminal cases. Appellant later filed a pro se petition for habeas corpus alleging that the sentences in these cases were illegal because the circuit court imposed a habitual-offender enhancement without proof that Appellant had committed more than one but less that four prior felonies. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was not within the purview of the habeas corpus remedy. View "Trammel v. Kelley" on Justia Law

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The Supreme Court affirmed Appellant's conviction of rape and second-degree sexual assault and sentence of life imprisonment and twenty years' imprisonment, respectively, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported the jury's conclusion that Appellant committed rape; (2) the circuit court did not abuse its discretion by not instructing the jury on the offense of attempted rape; and (3) the circuit court did not abuse its discretion by allowing a witness to testify at sentencing about child-abuse statistics. View "Caple v. State" on Justia Law

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The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.In his petition, Petitioner asserted that the prosecution withheld material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and withheld facts regarding information obtained during the police investigation. Petitioner later filed a motion asserting additional bases for issuance of the writ. The Supreme Court denied the petition and the motion, holding that Petitioner did not state sufficient allegations to satisfy issuance of the writ. View "Jones v. State" on Justia Law

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The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion for an independent action to set aside his conviction for fraud, holding that the trial court did not err in denying the motion on the basis that Defendant was precluded from seeking postconviction relief under Ark. R. Civ. P. 60(k).Defendant pleaded guilty to first-degree murder and was sentenced to life imprisonment. Defendant later filed a Rule 60(k) motion for an independent action to set aside his judgment for fraud upon the court, alleging that he did not agree to plead guilty in exchange for a life sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Rule 60 does not apply to criminal proceedings such as this one. View "Robinson v. State" on Justia Law