Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the trial court dismissing Appellant's pro se petition for writ of habeas corpus filed pursuant to Act 1780 of 2001, Ark. Code Ann. 16-1120-201 to -208, holding that Appellant failed to establish that he was entitled to relief.Appellant entered a plea of guilty to residential burglary, rape, and other crimes. More than twenty years after he was convicted, Defendant filed this habeas petition, asserting that he was innocent and seeking DNA testing. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant failed to rebut the presumption against timeliness; and (2) Appellant failed to make a prima facie showing that he was entitled to new scientific testing. View "Mahmoud v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first-degree murder and other crimes and his sentence of consecutive terms of life in prison for each murder, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the testimony of surviving victim Lajhonta Collier identifying Defendant as the perpetrator was erroneously admitted and that the State presented insufficient evidence to support the convictions. The Supreme Court affirmed, holding (1) substantial evidence supported the jury's verdict; and (2) the circuit court did not clearly err in determining that Defendant's pretrial identification was not constitutionally improper. View "Wilson v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that it lacked jurisdiction to reduce Defendant's sentence, holding that there was no error.In 1993, Defendant pleaded guilty to first-degree murder and was sentenced to a term of life in prison. Defendant was nineteen years old when he committed the murder. At issue was Defendant's postconviction motion to reduce his sentence, in which Defendant argued that Arkansas courts should expand their interpretation of the Eighth Amendment as it relates to sentencing young adults. The Supreme Court affirmed the circuit court's denial of the motion, holding that the circuit court did not err in concluding that no Arkansas law gave it jurisdiction to modify Defendant's sentence under the circumstances of this case. View "Robinson v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that there was no error in the trial court's denial of relief.In his postconviction petition, Appellant raised eight arguments. The Supreme Court affirmed the trial court's denial of the petition, holding (1) Appellant's Rule 37.1 petition was timely filed; (2) Appellant's challenges to his underlying guilty plea and conviction were not properly before the Court in this appeal; (3) the trial court did not err in finding that the denial of Appellant's request for an irretrievable-depravity instruction was not improper; and (4) Appellant's remaining arguments were without merit. View "Elliott v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in which he argued evidence was withheld in violation by Brady v. Maryland, 373 U.S. 83 (1963), holding that Petitioner failed to establish a ground for relief.Petitioner was convicted of manufacturing a controlled substance, possession of a controlled substance with intent to deliver, and possession of drug paraphernalia with intent to manufacture methamphetamine. At issue was Petitioner's coram nobis petition alleging a Brady violation. The Supreme Court denied the petition, holding that Petitioner failed to establish that he was entitled to the writ. View "Williams v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's Rule 37 petition alleging ineffective assistance of counsel during his criminal trial, holding that there was no error or abuse of discretion.Defendant was convicted of and sentenced to death for capital murder. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief arguing that his trial counsel were constitutionally ineffective for multiple reasons. The circuit court denied the petition. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Holland v. State" on Justia Law