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 denying and dismissing Appellant's petition for writ of habeas corpus, holding that because Appellant did not establish either that the sentencing orders implicated the jurisdiction of the circuit court or that they were facially invalid, the circuit court did not err in denying the petition. The circuit court denied Appellant's petition on the basis that Appellant had previously raised the same arguments in a prior habeas petition. The Supreme Court affirmed but on different grounds, holding (1) the circuit court clearly erred in determining that Appellant's Fair Sentencing of Minors Act claims were previously considered, but because Appellant's challenge was to his parole eligibility, he failed to establish that the writ should issue; and (2) Appellant's argument that his sentence was a grossly disproportionate punishment was not cognizable in a writ of habeas corpus. View "Proctor v. Payne" on Justia Law

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The Supreme Court affirmed Defendant's conviction of capital murder and sentence of death, holding that the circuit court did not err. Specifically, the Supreme Court held (1) the circuit court did not err in refusing to allow Defendant to represent himself where Defendant's request to self-representation was not unequivocal; (2) the circuit court did not err in refusing to give Defendant's non-model instruction stating that the jury had the option of extending mercy in assessing his punishment; and (3) the circuit court did not err in including two aggravated circumstances jury instructions offered by the State. View "Gardner v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for mistrial, holding that the circuit court's decision to admit into evidence a translation of a letter Defendant wrote in Spanish did not violate Ark. R. Evid. 1009 or Defendant's Sixth Amendment right to confrontation. Defendant was convicted of rape. On appeal, the Supreme Court held (1) there was no reversible error as a result of the bailiff's response to the jury foreman's question regarding the verdict forms, which resulted in the foreman mistakenly signing the forms for both rape and attempted rape, as shown by polling the members of the jury individually; and (2) Defendant did not have a constitutional right to confrontation because the translated statements were attributable to Defendant and, therefore, nontestimonial, and the accompanying affidavit to the letter substantially complied with Rule 1009. View "Garcia-Chicol 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 stated no ground in the petition on which the writ could issue. Appellant pleaded guilty to second-degree murder. Appellant later filed a petition for writ of habeas corpus, alleging that the Arkansas Department of Correction miscalculated his parole-eligibility status and that, therefore, the judgment of conviction was void. Appellant further alleged that he was unaware when he entered his guilty plea that his prior conviction for aggravated robbery would result in him not being eligible for parole. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's parole eligibility claims were not cognizable in this habeas proceeding; and (2) Appellant's challenge to his guilty plea was not within the purview of a writ of habeas corpus. View "Finney v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of rape, one count of kidnapping, and other offenses, holding that the circuit court did not err in denying Defendant's motion to suppress, denying Defendant's proffered jury instructions, or allowing Defendant to plead guilty over the State's objection. Specifically, the Supreme Court held (1) the circuit court properly denied Defendant's motion to suppress his custodial statement; (2) under the circumstances, the circuit court did not err in rejecting Defendant's proffered jury instructions on Class B felony kidnapping and on concurrent or consecutive sentencing; and (3) the circuit court did not err in refusing to accept Defendant's guilty plea when the prosecutor objected. View "Rickman 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 so that she may file a petition for writ of error coram nobis in her criminal case, holding that Petitioner's claims did not establish a ground for the writ. Petitioner was convicted of aggravated robbery and theft of robbery and was sentenced to an aggregate term of 480 months' imprisonment. This appeal concerned Petitioner's second coram nobis petition. In her petition, Petitioner argued that the lead investigator in the case withheld evidence from the defense and failed to notify the defense regarding primary pieces of evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petition, holding that Petitioner failed to state a cognizable ground for the writ. View "Joiner v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus filed under Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. Appellant was convicted of two counts of capital murder and, in a separate trial, one count of second-degree murder. In his habeas corpus petition, Appellant alleged that the judgment of conviction for capital murder was void because he was detained without lawful authority. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's request for habeas relief was clearly without merit. View "Hall v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's petition to correct an illegal sentence "imposed in an illegal manner," filed pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not err. Defendant was found guilty of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Defendant's sentences were enhanced under Ark. Code Ann. 5-64-408 for a subsequent controlled-substance conviction. Defendant was sentenced to 840 months' and 240 months' imprisonment, to be served consecutively. The court of appeals affirmed. In his petition to correct an illegal sentence, Defendant argued that the sentences imposed exceeded the statutory maximum for the offenses for which he was convicted. The trial court denied relief. The Supreme Court affirmed, holding that Defendant's sentences were legally enhanced under section 5-64-408(b), and Defendant did not establish that his sentences were facially illegal. View "Darrough v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. Appellant was convicted of capital murder and sentenced to life imprisonment without parole. Appellant later filed a petition for writ of habeas corpus alleging that the judgment was void because the felony information was signed by a deputy prosecutor rather than the prosecutor. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant's challenge to the validity of the felony information did not establish a ground for the writ. View "Randle v. Straughn" 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 establishing that he was entitled to coram nobis relief. In his petition, Petitioner asserted that the State withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963), by not turning over exculpatory evidence concerning DNA testing and a firearm that was not adequately tested by the State for fingerprints. The Supreme Court denied the petition, holding (1) the fact that certain scientific testing was not performed on an item in evidence did not constitute a showing that the testing was hidden by the State; and (2) Petitioner's remaining allegation was not within the purview of the writ. View "McKinney v. State" on Justia Law