Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court's failure to instruct the jury with the model verdict form on dispute accomplice status was reversible error under the third and fourth exceptions enumerated in Wicks v. State, 606 S.W.2d 366 (Ark. 1980). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence obtained during a search of his property; and (2) neither Wicks exception to the objection requirement applied under the circumstances of this case. View "Nowell v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and sentencing him to life plus an additional term of imprisonment as a result of sentencing enhancements, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion for a directed verdict; (2) the circuit court did not abuse its discretion by admitting an officer’s cell phone recordings of a surveillance video from a store; (3) the circuit court did not abuse its discretion by denying Defendant's motion for a new trial based upon jury misconduct; and (4) Defendant's remaining allegations of error were not preserved for appeal. View "Harris v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court admitting two 911 calls reporting a shooting and a dash cam video containing statements from an eyewitness during Defendant's criminal trial, holding that any error was harmless.After a jury trial, Defendant was convicted of first-degree murder, first-degree battery, and other crimes. After he was sentenced to life imprisonment plus fifteen years, Defendant filed a motion for a mistrial, which was deemed denied. The Supreme Court affirmed, holding (1) the circuit court properly ruled that the statements from the 911 calls were nontestimonial and thus admissible; (2) the circuit court erred in admitting the dash cam video, but the error was harmless beyond a reasonable doubt; and (3) Defendant's final two arguments were not preserved for appellate review. View "McNeil-Lewis v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Appellant of first-degree murder and other crimes and sentencing him to an aggregate term of two life sentences plus 835 years' imprisonment, holding that the State failed to demonstrate that Appellant was brought to trial within the twelve-month period required by Ark. R. Crim. P. 28.1(b).At issue on appeal was whether Appellant's constitutional right to a speedy trial, as embodied in Ark. R. Crim. P. 28.1, was violated when the State failed to bring him to trial within twelve months of the date of his arrest. The Supreme Court concluded that Appellant's right was indeed violated because he was held for a total of 405 days during which the speedy trial was not tolled, a total that exceeded the requisite 365-day period. View "Parker v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court finding Appellant's pro se petition to correct an illegal sentence was both untimely and without merit, holding that the court did not err in denying the petition.Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Twenty-four years after the mandate issued affirming Appellant's conviction, Appellant filed his petition to correct an illegal sentence. The trial court denied the petition, finding it to be both untimely and without merit. The Supreme Court affirmed, holding that twenty-four years exceeded the time to challenge how Appellant's sentences were imposed. View "Hussey v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Petitioner's pro se petition for postconviction relief alleging that his sentence was illegal pursuant to Ark. Code Ann. 16-90-111, holding that none of Petitioner's allegations established that his sentence was facially illegal.After a jury trial, Petitioner was convicted of capital murder, aggravated robbery, theft of property, and fleeing and was sentenced to to term of life imprisonment without parole. In his petition for postconviction relief, Petitioner made a series of claims regarding trial counsel and a claim of judicial bias. The Supreme Court affirmed the denial of the petition, holding that the trial court properly denied Petitioner's postconviction claims. View "Jefferson v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for postconviction relief filed pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not er in denying Appellant's petition to correct an illegal sentence.Appellant was found guilty of first-degree murder and committing a terroristic act and was sentenced to two life sentences. Appellant later filed his petition to correct an illegal sentence. The trial court denied the petition on the grounds that it was not timely filed and that the sentence imposed was valid. The Supreme Court affirmed, holding that Appellant was not entitled to relief. View "Starling v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that none of the allegations raised by Appellant established that his sentence was facially illegal.Appellant entered a guilty plea to four counts of aggravated robbery and other offenses and was sentenced to an aggregate term of 420 months' imprisonment. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and a pro se petition for reduction of sentence pursuant to Ark. Code Ann. 16-90-111. In his petition to correct an illegal sentence Appellant argued, inter alia, that his sentence was illegal because he was not eligible for a suspended sentence due to his status as a habitual offender. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief to correct an illegal sentence because his sentences were not illegal. View "Carter v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying and dismissing Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err in dismissing the petition.Appellant was convicted of first-degree felony murder and other crimes and sentenced as a habitual offender to an aggregate term of life imprisonment. Appellant later brought his petition for postconviction relief asserting that his trial counsel was ineffective in several respects. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his counsel provided ineffective assistance during trial. View "Price v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's petition for writ of habeas corpus, holding that Appellant's sentencing order was not facially invalid.In 1981, at the age of seventeen, Appellant was charged with two counts of capital murder. The circuit court sentenced Appellant to a term of life imprisonment. In 2020, Appellant filed a petition for a writ of habeas corpus asserting that he had been held unlawfully pursuant to Miller v. Alabama, 567 U.S. 460 (2010). The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant's argument was barred by the issue-preclusion element of res judicata. View "Brown v. State" on Justia Law