Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus filed pursuant to Ark. Code 16-112-101 to -123, holding that Appellant was not entitled to relief on his claims of error.Appellant, who was eighteen years old when he committed murder, pleaded guilty to capital murder and was sentenced to life parole. Four decades later, Appellant filed his pro se petition for writ of habeas corpus, seeking an expansion of the holding in Miller v. Alabama, 567 U.S. 460 (2012), to individuals between the ages of eighteen to twenty-one. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the petition without holding a hearing. View "Gibbs v. Payne" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order dismissing Appellant's appeal from the district court absent a conviction as required by Ark. R. Crim. P. 36(a), holding that the district court illegally imposed court costs and probation in violation of Appellant's state and federal constitutional due process rights and his federal and state constitutional right to a trial.Appellant pled guilty to carrying a weapon in a publicly owned building. The district court ordered Appellant to pay court costs of $140 and told Appellant if there were no further charges within thirty days the charge would be dismissed. The court dismissed the case at the end of thirty days for lack of jurisdiction on the grounds that there was no underlying conviction. The Supreme Court reversed in part, holding that the court had jurisdiction to hear Appellant's challenge to the legality of his de facto sentence, and Appellant should have been heard on the merits. View "Gillette v. City of Fort Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment, granted appellate counsel's motion to withdraw as counsel, and remanded the case for a correction of a clerical error in the sentencing, holding that no reversible error occurred in the proceedings below.After his conviction, Defendant filed a timely appeal, and his attorney filed a no-merit brief. The Supreme Court declined to grant relief, holding (1) the circuit court did not err in denying Defendant's motion for a directed verdict and his renewed motion for directed; (2) the circuit court did not abuse its discretion in sustaining the State's hearsay objection to certain testimony; and (3) while an error in the sentencing order was not grounds for reversal, remand was required for correction. View "Humphry v. State" on Justia Law

The Supreme Court affirmed in part and reversed and dismissed in part a sentencing order convicting Appellant of twenty-five counts of possessing or viewing matter depicting sexually explicit conduct involving a child and sentencing him to forty-two years' imprisonment, holding that certain counts are reversed and dismissed for a failure of proof that the images underlying those counts contained matter depicting or incorporating the image of a child as defined by Ark. Code Ann. 5-27-601(1).Pursuant to a search warrant, law enforcement officers searched Defendant's residence and seized several electronic devices. A forensic examination of the devices revealed images that were pornographic in nature involving children. Some were computer-generated imagery (CGI) and some were actual photographs. Among his allegations of error on appeal, Appellant argued that the individuals depicted in the CGI did not meet the legal definition of a "child." The Supreme Court agreed and reversed and dismissed counts 1, 15-16, and 23-30, holding that the State failed to present evidence on each of those counts that the underlying CGI images depicted or incorporated the images of a child, and therefore, the evidence was insufficient to sustain those convictions. View "Lewis v. State" on Justia Law

The Supreme Court dismissed this appeal brought by the State claiming an error in Defendant's criminal proceedings regarding a speedy-trial ruling, holding that the State's appeal was not authorized under Ark. R. App. P.-Crim. 3.Defendant was charged for driving while intoxicated. Defendant later filed a motion to dismiss the prosecution based on a speedy-trial violation. The trial court granted the motion, ruling that the charges be dismissed based on a speedy-trial violation. The State appealed, essentially challenging the circuit court's findings of fact regarding the speedy-trial calculation. The Supreme Court dismissed the appeal, holding that the appeal was not authorized under Rule 3 because it did not present an issue of interpretation of a criminal rule that would have widespread ramifications. View "State v. Pate" on Justia Law

The Supreme Court affirmed the order of the circuit court entering judgment upon a jury verdict finding Defendant guilty of rape and sentencing him to life in prison, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the State intentionally circumvented his right to confront vital witnesses by improperly allowing into evidence a surreptitious recording made by Defendant's roommate and that the recording contained inadmissible hearsay. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the rape conviction; and (2) the circuit court did not err in admitting the recording into evidence. View "Wallace v. State" on Justia Law

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

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

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

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