Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the decision of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.After a jury trial, Appellant was convicted of aggravated robbery and theft of property. In his pro se petition for writ of habeas corpus Appellant argued that a different standard of review should be applied to habeas cases, he was actually innocent, his constitutional rights were violated, and the evidence was insufficient to sustain his conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ or that the circuit court erred by denying habeas relief. View "Boyd v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's second petition for a writ of habeas corpus, holding that Appellant's second petition was an abuse of the writ.Appellant pleaded nolo contendere to multiple felony counts in three separate criminal cases. In his first habeas petition, Appellant alleged that the sentences in two cases were illegal because a habitual-offender enhancement was improperly imposed. The circuit court denied the petition. In his second habeas petition, Appellant raised the same arguments he raised in the circuit court. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition. View "Trammel v. Payne" on Justia Law

The Supreme Court affirmed the circuit court's judgment denying and dismissing Appellant's pro se petition for a writ of habeas corpus, holding that Appellant's claim lacked factual support and failed to demonstrate entitlement to the writ.Appellant entered a guilty plea to rape and sexual assault in the first degree. Appellant subsequently filed several petitions for habeas relief. In the habeas petition at issue before the Supreme Court Appellant alleged that he was convicted twice for the same offense, in violation of the constitutional prohibition against double jeopardy. The Supreme Court denied relief, holding that Appellant's claim lacked merit. View "Morgan v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in dismissing the habeas petition.Appellant was convicted of capital murder and first-degree battery and sentenced to life in prison. In his habeas petition, Appellant argued that his capital murder conviction was illegal because his sentence exceeded the maximum sentence for the crime designated in his arrest warrant of first-degree murder. The circuit court dismissed the claim. The Supreme Court affirmed, holding that the circuit court did not clearly err by denying and dismissing Appellant's petition for habeas relief. View "Grant v. Payne" on Justia Law