Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of error coram nobis and his petition for writ of habeas corpus, holding that there was no error or abuse of discretion.Appellant was convicted of rape and first-degree battery and sentenced to life imprisonment. In his petition for writ of error coram nobis Appellant argued that the outcome of the proceedings would have been different had certain testimony been allowed. The circuit court denied the petition. For reversal, Appellant argued that the Supreme Court should adopt the "tentative expansion" of the writ of error coram nobis set forth in Strawhacker v. State, 500 S.W.3d 716 (Ark. 2016). The Supreme Court affirmed, holding (1) because Appellant requested an expansion of the writ that already existed, his argument was moot; and (2) the circuit court did not abuse its discretion in denying coram nobis relief. View "Strawhacker 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 the circuit court did not err in denying the petition.Appellant was found guilty of, among other things, four counts of aggravated robbery and other convictions. Appellant was sentenced to an aggregate term of 240 years' imprisonment. In his writ of habeas corpus, Appellant argued, among other things, that incorrect dates rendered the judgment and commitment order illegal on its face. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not allege a cognizable claim and failed to demonstrate probable cause for issuance of the writ. View "Hutcherson v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111 in which Appellant alleged that his sentence was illegal, holding that the trial court did not err in finding that Appellant's claims were untimely and that he otherwise failed to demonstrate that his sentences were facially illegal.Appellant pleaded guilty to two counts of first-degree murder and was sentenced to an aggregate term of forty-five years' imprisonment. Appellant later brought this petition, arguing that his sentences departed from the presumptive sentence for first-degree murder as prescribed by Arkansas's sentencing statutes. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant's sentences were facially legal and that the trial court did not clearly err when it denied Manuel's petition. View "Manuel v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's petition for writ of habeas corpus in which he argued that the circuit court erred by not finding that the trial court's impermissible stacking of two statutes resulted in double-penalty enhancement, holding that the sentencing order was incomplete.Appellant pled guilty to third-degree domestic battery and was sentenced as a habitual offender to 144 months' imprisonment. Appellant later brought this habeas petition, alleging that the trial court impermissibly stacked two penalty-enhancement statutes when he was sentenced for felony domestic battery. The circuit court denied the petition. The Supreme Court reversed, holding that the circuit court's decision regarding the facial validity of the sentencing order was erroneous because the trial court did not enter a complete sentencing order. View "Ray v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. Code Ann. 16-90-111, in which he argued that the judgment in his criminal case was facially illegal because his sentence of life imprisonment exceeded the maximum sentence authorized for a Class Y felony, holding that the sentence imposed was not an illegal sentence.In an earlier petition for writ of habeas corpus Appellant raised the same claim that he brought in his petition for postconviction relief. The Supreme Court had concluded that Appellant's life sentence was clearly within the sentencing range for the offense of first-degree murder. As to Appellant's postconviction motion, the Supreme Court denied relief, holding that Appellant was sentenced within the permitted statutory range for first-degree murder, and Appellant failed to establish that the sentence was illegal on its face. View "McArty v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law

The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant's petition for leave to proceed in forma pauperis to pursue a pro se petition for writ of error coram nobis, holding that the circuit court abused its discretion in denying Appellant's request to proceed in forma pauperis when he also filed a coram nobis petition.On appeal, Appellant argued that the circuit court acted arbitrarily and abused its discretion by denying his request to proceed in forma pauperis when he had properly filed his coram nobis petition. The Supreme Court reverse the circuit court's denial of the petition, holding that the circuit court abused its discretion by failing to address the merits of the underlying pro se petition for writ of error coram nobis. View "Randle v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus in which he alleged that he was actually innocent of the crimes for which he was convicted, holding that Appellant failed to state a cognizable claim for habeas relief.Appellant was convicted of capital-felony murder with aggravated robbery as the underlying offense and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant later filed this habeas corpus petition, alleging that he was actually innocent of the crimes and also raised multiple allegations of due process violations and trial error. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied Appellant's petition for failure to demonstrate probable cause for issuance of the writ. View "Goodwin v. Payne" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Petitioners' petition for declaratory judgment, writ of mandamus, and request for injunctive relief, holding that the Arkansas Division of Correction wrongfully calculated the parole eligibility on Petitioners' fifteen-year sentence enhancement for committing a felony with a firearm.Petitioners were jointly tried and convicted for their participation in a kidnapping and battery and received differing sentences. Petitioners brought this petition objecting to the Division's calculation of their parole eligibility. The Supreme Court agreed and reversed, holding that parole eligibility for Petitioners should be calculated based on Ark. Code Ann. 16-93-1301. View "Perry v. Payne" on Justia Law