Justia Criminal Law Opinion Summaries

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

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