Justia Criminal Law Opinion Summaries

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

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