Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

The Supreme Court affirmed the denial of Defendant's petition for postconviction relief alleging five grounds for relief from the judgment of conviction of first-degree murder and sentence of life imprisonment, holding that there was no error.The circuit court denied Defendant's claims of ineffective assistance of counsel, the only claims alleged in his postconviction motion, all of which it denied without an evidentiary hearing except one. The Supreme Court affirmed, holding that the performance of Defendant's trial counsel was not deficient and that Defendant was not entitled to relief on any of his allegations of error. View "Arnold v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's Ark. R. Crim. P. 37.1 petition for relief following an evidentiary hearing, holding that the circuit court did not err in denying the petition.After a jury trial, Petitioner was convicted of capital murder, aggravated robbery, and a firearm enhancement. In his petition for postconviction relief, Petitioner claimed that he received ineffective assistance of counsel in several respects. The circuit court denied the petition after posthearing briefs were held. The Supreme Court affirmed, holding that the circuit court did not clearly err in finding that Petitioner was not entitled to relief. View "Pree v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's motion for new trial and petition for habeas corpus, holding that there was no error in the proceedings below.Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant later filed a petition for a writ of habeas corpus, which the circuit court dismissed. Appellant then filed a motion for a new trial under Ark. R. Civ. P. 59, which the circuit court denied and dismissed. The Supreme Court affirmed the order denying Appellant's habeas petition and his motion for new trial, holding that Appellant was not entitled to relief on any of his claims of error. View "Scott v. Payne" on Justia Law

The Supreme Court affirmed the jury verdict in circuit court finding Defendant guilty of failure to comply with sex-offender reporting requirements, holding that the circuit court did not err, prejudicially or otherwise, in the proceedings below.On appeal, Defendant argued that the trial court erred in denying his timely motions for a directed verdict and in finding that he was a person required to register as a sex offender. The Supreme Court disagreed, holding that the circuit court (1) did not err in denying Defendant's motion for a directed verdict challenging the sufficiency of the evidence; and (2) did not err in finding that Defendant was required to register as a sex offender. View "Lenard v. State" on Justia Law