Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for a copy of his trial transcript at public expense, holding that the circuit court properly concluded that Appellant had failed to demonstrate a compelling need for a copy of his trial transcript.Appellant was found guilty of two counts of aggravated robbery and one count of theft of property and sentenced as a habitual offender to life imprisonment. In his motion filed in the trial court Appellant requested copies of his trial transcript from his criminal case at public expense. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to demonstrate a compelling need for relief. View "Spearman v. State" on Justia Law

The Supreme Court granted in part and denied in part Petitioner's pro se petition for writ of mandamus for extraordinary writ for expedited consideration and/or for writ to issue relief, holding that Petitioner's request for a writ directing the court to dispose of the matter is granted.Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. At issue was Petitioner's pro se petition for writ of mandamus for extraordinary writ for expedited consideration and/or for writ to issue relief. The Supreme Court granted the writ of mandamus and denied the request for expedited consideration and writ to issue relief and denied the subsequent motion, holding (1) mandamus does lie as to the court's ministerial duty to timely act on pleadings filed; and (2) Petitioner was not entitled to relief on his remaining requests. View "Evans v. State" on Justia Law

The Supreme Court affirmed the trial court's denial and dismissal of Appellant's third pro se petition for writ of habeas corpus, holding that the trial court did not err in denying relief.In 1992, Appellant was found guilty of rape and theft of a van and sentenced to an aggregate term of thirty-five years' imprisonment. In his third pro se petition for writ of habeas corpus filed pursuant to Act 1780 of 2001, Ark. Code Ann. 16-112-201 to -208 Appellant sought scientific testing of evidence from his criminal case. The circuit court denied relief. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "Makkali v. State" on Justia Law

The Supreme Court affirmed the supplemental order of the circuit court denying Ark. R. Crim. P. 37 relief, holding that the circuit court did not err.Defendant was convicted of capital murder and sentenced to death. Defendant later sought postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding (1) Defendant was not denied the right to a fair and impartial jury; (2) the circuit court did not clearly err in denying Defendant's ineffective assistance of counsel arguments; (3) Defendant's challenges to the third death-penalty verdict form did not constitute grounds for relief under Rule 37; (4) Defendant's challenges to the verdict forms did not constitute grounds for relief; and (5) Defendant's remaining allegations of error were without merit. View "Gay v. State" on Justia Law