Justia Criminal Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for writ of habeas corpus, holding that Petitioner's statutory and constitutional claims did not raise jurisdictional issues that entitled him to habeas relief.Petitioner was convicted of capital murder and first-degree battery and sentenced to a life sentence plus consecutive twenty-four sentences. The Supreme Court affirmed on direct appeal. Petitioner later brought this petition alleging that he was not named in the body of the criminal information and that he was not identified in the document, and therefore, the trial court lacked jurisdiction over him. The circuit court denied the habeas corpus petition. The Supreme Court affirmed, holding that the trial court had personal and subject-matter jurisdiction over Petitioner. View "Lee v. Payne" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of multiple counts of rape, second-degree sexual assault, sexual indecency with a child, engaging a child in sexually explicit conduct for use in visual or print medium and other offenses, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported Defendant's forty-one convictions; (2) Defendant's argument that the State improperly relied on a religious text to urge a conviction during closing argument was not preserved for appeal; and (3) Defendant's arguments regarding his sentence of life imprisonment plus 488 years were not preserved for appellate review. View "Break v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder and sentencing him to life imprisonment, holding that not prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported Appellant's capital murder conviction; (2) the circuit court did not abuse its discretion in the guilt phase of trial by excluding the victim's emergency room medical records and a death certificate; and (3) Appellant's argument that the deputy chief medical examiner provided invalid forensic testimonial evidence and resulted in his conviction was not preserved for appeal. View "May v. State" on Justia Law

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The Supreme Court affirmed the decision of the Arkansas Client Security Fund Committee denying Appellant's application for the reimbursement of client funds, holding that the Committee properly denied Appellant's application for relief because his application was untimely.Appellant, who was incarcerated for second-degree sexual assault, filed an application for relief with the Fund seeking $2500 in reimbursement from his former attorney Thomas Wilson. The Committee denied the application pursuant to Rule 4(B) of the Rule of the Client Security Fund Committee. The Supreme Court affirmed, holding that Appellant's application was not filed within the three-year time frame set forth in Rule 4(B). View "Curran v. Ark. Client Security Fund" on Justia Law

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The Supreme Court dismissed the order of the circuit court denying Appellant's motion for new trial based on allegations of juror misconduct, holding that the motion was clearly untimely, and therefore, the circuit court did not have authority to act on Appellant's motion when it entered orders in this action.In 2004, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 2018, Appellant filed a petition for writ of habeas corpus and motion for new trial alleging juror misconduct. The trial judge dismissed the habeas petition without prejudice and denied the motion for new trial. The Supreme Court dismissed the appeal, holding that Appellant's motion for new trial was untimely, and the circuit court lacked jurisdiction to consider the motion. View "Herron v. Ark. Department of Corrections" on Justia Law

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The Supreme Court reversed the judgment of the circuit court granting Petitioner's motion for judgment on the pleadings, entering judgment in Petitioner's favor for the relief requested in his petition, and denying the Director of the Division of Correction's motion for summary judgment, holding that the circuit court erred.Petitioner pleaded guilty to first-degree murder and aggravated assault. After the General Assembly passed the Fair Sentencing of Minors Act (FSMA), which contained parole-eligibility provisions that applied retroactively to Petitioner, Petitioner filed a petition for declaratory judgment, injunctive relief, and mandamus relief seeking to resolve any uncertainty regarding the FSMA as applied to him. The circuit court granted Petitioner's motion for judgment on the pleadings and denied the Board's motion for summary judgment, finding that Ark. Code Ann. 16-93-621(a)(2)(A) applied retroactively to Petitioner's sentences. The Supreme Court reversed, holding that the circuit court erred in its interpretation of section 16-93-621(a) and by finding that Petitioner was parole eligible after serving twenty-five years' imprisonment. View "Arkansas Parole Bd. v. Johnson" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's multiple claims of ineffective assistance of counsel, holding that the circuit court did not err on Appellant's seven separate claims of ineffective assistance of counsel.Appellant was convicted of second-degree murder and sentenced to life in prison. Appellant later filed a petition under Ark. R. Crim. P. 37 arguing that the circuit court erred on seven distinct allegations of ineffective assistance of counsel. The Supreme Court affirmed, holding that none of Appellant's arguments on appeal had merit and that the circuit court did not err in denying postconviction relief. View "Gentry v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of capital murder, abuse of a corpse, and theft of property, holding that Defendant was not entitled to reversal of his convictions based on his allegations of error.On appeal, Defendant argued, among other things, that the district court erred when it denied his directed verdict motion on the charges. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case excluded every reasonable hypothesis other than Defendant's guilt; (2) the circuit court did not err in denying Defendant's motion to suppress; and (3) the circuit court did not abuse its discretion by admitting into evidence autopsy photos. View "Cone v. State" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court convicting Defendant of two counts of rape, sexual assault in the second degree, and sexually grooming a child, holding that remand was required for entry of a corrected sentencing order in which Defendant was not assessed a cybercrime fee.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's convictions for rape and sexually grooming a child; (2) the circuit court did not err in denying Defendant's motion to introduce certain evidence under the rape-shield statute, Ark. Code Ann. 16-42-101; and (3) the circuit court erred by assessing a $150 cybercrime fee because the State failed to meet the requirements of Ark. Code Ann. 5-4-706(b). View "Hartley v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying the State's motion to dismiss Defendant's appeal of a district court judgment finding him guilty of two misdemeanors, holding that there was no error.In its motion to dismiss Defendant's appeal, the State claimed that Defendant had failed strictly to comply with the requirements of Ark. R. Crim. P. 36(c), and therefore, the circuit court lacked subject matter jurisdiction over the appeal. After a hearing, the circuit court denied the motion to dismiss, finding that Defendant timely filed the record within thirty days of the entry of judgment in the district court. The Supreme Court affirmed, holding that the circuit court acquired jurisdiction of Defendant's appeal upon the timely filing of the certified district court record. View "State v. Voast" on Justia Law