Justia Criminal Law Opinion Summaries

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

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