Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for declaratory relief, holding that Appellant failed to demonstrate that Appellees acted in contravention of the statutes pertaining to his parole eligibility.After a bench trial, Appellant was convicted of first-degree battery and second-degree battery and sentenced to an aggregate term of 264 months' imprisonment. In his petition for declaratory relief Appellant challenged the determination of his parole eligibility by officials with the Arkansas Department of Correction. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in dismissing the declaratory judgment action. View "Harkuf v. Marony" 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, holding that Petitioner failed to establish sufficient grounds for issuance of the writ.Petitioner was found guilty of theft by receiving and fleeing and sentenced as a habitual offender to thirty-five years' imprisonment. In his coram nobis petition Petitioner raised seven claims for relief. The Supreme Court denied relief, holding that Petitioner's claims either were not cognizable in coram nobis proceedings or were without merit. View "Brown 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, holding that none of Petitioner's claims established a ground for the writ.Petitioner was convicted of two counts of capital murder and one count of a terroristic act. Petitioner later brought this coram nobis petition alleging that evidence was withheld by the State in violation of Brady v. Maryland, 373 U.S. 83 (1963), trial court error, and ineffective assistance of counsel. The Supreme Court denied the petition, rendering moot Petitioner's motion for appointment of counsel, holding that Petitioner failed to establish that he was entitled to relief. View "Stephenson v. State" on Justia Law

The Supreme Court affirmed the sentence imposed upon Defendant in connection with his plea of guilty to failure to register as a sex offender and plea of guilty to being a habitual offender, holding that the circuit court did not impose an illegal, fine-only sentence in violation of the habitual offender statute.After accepting Defendant's guilty plea, the circuit court made specific findings for leniency and proclaimed a sentence of only a $10,000 fine and no incarceration. The Supreme Court affirmed, holding (1) a plain reading of the statute in effect at the time Defendant committed the crime permitted the circuit court to impose a fine, imprisonment, or both; and (2) the circuit court did not err in imposing a fine-only sentence. View "State v. Mason" on Justia Law

The Supreme Court affirmed Defendant's convictions on three counts of capital murder and felony-firearm enhancement, for which Defendant was sentenced to three consecutive terms of life imprisonment without parole, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the verdicts; (2) Defendant was not prejudiced by the circuit court’s handling of a jury note and the replaying of his custodial interview during his absence; (3) Defendant's argument that his defense counsel had a conflict of interest due to prior representation of a State’s witness was without merit based on Defendant's on-the-record statement that he wanted counsel to remain his attorney; and (4) the trial court did not err by denying Defendant's motions to suppress his statements to police. View "Lewondowski v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's petition for writ of habeas corpus, holding that there was no error.After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. The court sentenced Appellant as a habitual offender to an aggregate term of life imprisonment without parole. In his habeas corpus petition, Appellant claimed, among other things, that his convictions and sentences were invalid because the prosecutor did not sign the criminal information. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claims for habeas relief. View "Gardner v. Payne" on Justia Law

The Supreme Court affirmed the circuit court's decision denying Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err by denying Appellant's petition.Appellant, an inmate serving several sentences, filed his petition to correct an illegal sentence alleging that the sentences imposed in his 2011 convictions and in his revocation were null and void because he was illegally arrested. The circuit court denied the petition, concluding that the petition was without merit. The Supreme Court affirmed, holding that the circuit court's judgment was not clearly erroneous. View "Mister 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 alleging that his conviction was void because his sentences exceeded the maximum statutory sentence for a Class C felony, holding that there was no error.Appellant pled guilty to, among other things, ten counts of possession and distribution of sexually explicit images of children and nineteen counts of possession and distribution of sexually explicit images of children. In his habeas corpus petition Appellant alleged that his conviction was void because his two consecutive sentences for twenty-nine counts of possessing matter depicting sexually explicit images of a child exceeded the maximum statutory sentence for a Class C felony. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's sentence of 240 months’ imprisonment each for ten counts and nineteen counts of possession of matter depicting sexually explicit images of children did not exceed the maximum penalty for those offenses. View "Osburn v. Gray" on Justia Law

The Supreme Court denied Petitioner's pro se fourth petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that the petition failed to contain facts that would support a cognizable claim for issuance of the writ.Petitioner was found guilty of residential burglary and rape and sentenced as a habitual offender to an aggregate term of 900 months' imprisonment. At issue on appeal was the denial of Petitioner's fourth pro se coram nobis petition, in which he alleged that the State falsified or failed to disclose evidence against him. The court of appeals affirmed. The Supreme Court affirmed, holding that Petitioner did not meet the criteria for granting the petition. View "Noble v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by Appellees - Arkansas Parole Board, John Felts, and Andy Shock - in Appellant's action filed pursuant to the Administrative Procedure Act (APA), Ark. Code Ann. 25-15-201 through 25-15-220, holding that Appellant failed to state a sufficient basis for judicial review under the APA.Appellant pleaded guilty to the sexual abuse of a fifteen-year-old and was sentenced to thirty years' imprisonment. Years later, the parole board denied Appellant parole for a two-year period of time. Appellant filed a petition for judicial review from the denial of his parole under the APA, alleging that Appellees failed to adhere to parole statutes and the APA, in violation of his due process rights. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it dismissed Appellant's complaint for failing to state a claim for relief pursuant to the APA. View "Wood v. Arkansas Parole Board" on Justia Law