Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's convictions of aggravated robbery and theft of property and his sentence of life in prison as a habitual offender, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that there was insufficient to support his convictions for both crimes and that the circuit court erroneously concluded that his earlier Kansas conviction was comparable for sentencing purposes to an Arkansas serious felony involving violence. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the convictions; and (2) the circuit court did not err in determining that Defendant's Kansas burglary conviction qualified as a prior felony involving violence for sentencing purposes. View "Wright v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus filed pursuant to Ark. Const. art. II, 11 and Ark. Code Ann. 16-112-101 to -123, holding that Appellant failed to state a cognizable claim for habeas relief.In 1994, Appellant was convicted of raping his twelve-year-old daughter and sentenced as a habitual offender to sixty years in prison. In his petition for a writ of habeas corpus Appellant alleged, for purposes of this appeal, that he was actually innocent. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the petition without holding a hearing. View "Wilson v. State" on Justia Law

The Supreme Court dismissed this appeal for lack of jurisdiction, holding that this Court lacked jurisdiction over the appeal.Appellant filed two pleadings in his criminal case, both a motion to vacate an illegal sentence and a civil complaint in which Appellant sought injunctive relief and damages based on an ongoing violation of the Interstate Agreement on Detainers. The circuit court dismissed both pleadings, finding that the postconviction petition was untimely and that Appellant failed to state facts entitling him to relief. The Supreme Court affirmed, holding that the circuit court lacked jurisdiction to address the merits of Appellant's postconviction petition. View "Woodward v. State" on Justia Law

The Supreme Court affirmed the sentencing order of the trial court imposing a life sentence following Appellant's resentencing hearing for a capital murder that he committed as a juvenile, holding that there was no error.For his sole point on appeal, Appellant argued that the circuit court clearly erred in imposing the maximum sentence allowable by statute after weighing the factors set forth pursuant to Miller v. Alabama, 567 U.S. 460 (2012). The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in imposing a life sentence, which under the Fair Sentencing of Minors Act of 2017 meant life with the possibility of parole after thirty years. View "Williams v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus, holding that there was no error.In 2009, Appellant was convicted of six counts of possessing matter depicting sexually explicit images of a child. The court sentenced him to six consecutive ten-year sentences. In his petition for a writ of habeas corpus, Appellant raised the same arguments that he previously raised in his prior petition for pro se relief. The circuit court dismissed the habeas petition. The Supreme Court affirmed, holding that the trial court's decision to deny Appellant's writ for habeas corpus was not clearly erroneous. View "Fischer v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court granting Appellee's motion to dismiss Appellant's petition for writ of mandamus seeking an order directing Appellee, counsel and representative of the Arkansas crime lab, to forward copies of his victim's autopsy photographs directly to him, holding that circuit court did not err.Appellant was found guilty of murder in the first degree and sentenced to life imprisonment. In 2019, Appellant made a request to the crime lab for documents in its possession related to his criminal trial and conviction, including the photographs and diagrams of the victim's autopsy. When the materials were provided to Appellant but the photographs were withheld as contraband Appellant brought this mandamus petition seeking the photographs. The circuit court granted Appellee's motion to dismiss. The Supreme Court affirmed, holding that Appellant did not demonstrate a right to possession of the autopsy photographs or that Appellee failed to perform a duty under Ark. Code Ann. 12-12-312. View "McArty v. McLaurin" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder, kidnapping, aggravated robbery, and theft of property but remanded for the circuit court to correct the sentencing order, holding that there was no reversible error.Specifically, the Supreme Court held (1) the circuit court did not err in denying Appellant's motion for directed verdict on the capital-murder, kidnapping, and aggravated-robbery charges; (2) the circuit court did not abuse its discretion in denying Defendant's motion to suppress; (3) due to a discrepancy between the sentencing order and the pronouncement of sentence, this matter must be remanded for the court to correct the order; (4) the circuit court did not abuse its discretion in admitting three exhibits over Appellant's hearsay objections; (5) the circuit court did not abuse its discretion by allowing the State to question Appellant about three prior bad acts; and (6) Appellant was not entitled to relief on his remaining claims of error. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of capital murder, kidnapping, aggravated robbery, and theft of property, holding that no prejudicial error occurred.Specifically, the Supreme Court held that the circuit court did not abuse its discretion in (1) refusing Appellant's proposed jury instructions regarding lack of criminal responsibility; (2) admitting photographs of the victim's remains; (3) denying Appellant's motion in limine seeking to prevent the prosecution from claiming to represent “the people”; and (4) declining to grant Appellant's motion for a mistrial when the prosecution told the jury that Appellant never once said he was sorry. View "Mackrell 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 his criminal case and his motion for appointment of counsel, holding that Petitioner failed to establish sufficient grounds for issuance of the writ.In his coram nobis petition, Petitioner argued that the State violated Brady v. Maryland, 373 U.S. 83 (1963), by concealing from him the full contents of his criminal case file. The Supreme Court denied the petition, holding that Petitioner failed to overcome the presumption that the judgment of conviction was valid. View "McArty v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for a writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101 to -123, holding that Appellant's allegations were not cognizable in a habeas proceeding.Appellant, who was incarcerated for aggravated robbery, filed a habeas petition alleging that the trial court placed supervisory conditions on his suspended sentence that controverted the suspended sentence into an illegal imposition of probation after the completion of a term of imprisonment. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was being illegally detained within the circuit court's jurisdiction. View "Henderson v. Payne" on Justia Law