Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Petitioner failed to demonstrate entitlement to Rule 37.1 relief.After a jury trial, Petitioner was convicted of capital murder and two counts of first-degree battery. The convictions were affirmed on appeal. In his petition for postconviction relief Petitioner argued, among other things, that he was subject to an unlawful arrest, that his due process rights were violated, and that he was denied effective assistance of appellate counsel. The trial court denied relief. The Supreme Court affirmed, holding that Petitioner failed to demonstrate entitlement to Rule 37.1 relief. View "Braud v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant's claim did not fall within the purview of habeas proceedings.After a jury trial, Appellant was convicted of capital murder and sentenced to life in prison with the possibility of parole. The Supreme Court affirmed. In his habeas petition, Appellant argued that the speedy-trial provision of the Interstate Agreement on Detainers Act, Ark. Code Ann. 16-95-101, was violated in his case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant's claims were not within the purview of habeas proceedings. View "Green v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for a writ of habeas corpus filed under Ark. Code Ann. 16-112-101, holding that Appellant's arguments on appeal failed to raise cognizable claims for habeas relief.Appellant pled no contest to one count of conspiracy to commit rape and seven counts of possessing matter depicting sexually explicit images involving a child. Appellant later filed a petition for a writ of habeas corpus, which the circuit court denied. The Supreme Court affirmed, holding that the allegations failed to state a claim for habeas relief, and therefore, the circuit court did not clearly err when it denied and dismissed the habeas petition. View "Myers v. Payne" on Justia Law

The Supreme Court affirmed the order of the trial court denying and dismissing Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentences were illegal.After a jury trial, Appellant was convicted of second-degree murder and sentenced as a habitual offender to eighty years' imprisonment. In his petition to correct an illegal sentence, Appellant asserted that the application of Ark. Code Ann. 5-4-501(c) to enhance his sentence was illegal and that the enhanced sentence violated the prohibition against the ex post facto application of criminal statutes. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his enhanced sentence was an illegal sentence pursuant to section 16-90-111. View "Rainer v. State" on Justia Law