Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the trial court's judgment denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant's claims lacked merit.Appellant was convicted of capital murder and sentenced as a habitual offender to life imprisonment without parole. In his postconviction petition, Appellant argued, among other things, that his counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his allegations of error. View "Thomas v. State" on Justia Law

The Supreme Court reversed the order of the circuit court acquitting Defendant by reason of mental disease or defect of one count of theft of property and two counts each of kidnapping and first-degree false imprisonment of two minors, holding that the circuit court erred by failing to require Defendant to register as a sex offender.The State charged Defendant with theft of property and first-degree false imprisonment. The circuit court concluded that Defendant should be acquitted due to lack of criminal responsibility and found that Defendant should not be required to register as a sex offender. The State appealed, arguing that the circuit court erred by declining to require Defendant to register as a sex offender. The Supreme Court agreed and reversed, holding that the circuit court erred by not requiring Defendant to register as a sex offender in its judgment of acquittal. View "State v. Scott" on Justia Law

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.After a jury trial, Petitioner was convicted of first-degree murder and sentenced to 540 months' imprisonment. In Petitioner's pro se second coram nobis petition Petitioner alleged, among other things, that insufficient evidence supported his conviction and that trial counsel was ineffective. The Supreme Court denied the petition, which rendered Petitioner's motion for appointment of counsel moot, holding that Petitioner's claims were outside the purview of coram nobis proceedings. View "Carroll 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, holding that there were no grounds stated in either the petition filed in the circuit court or in Appellant's appellate arguments on which a writ of habeas corpus could issue.Appellant pleaded guilty to one count of first-degree domestic battery and two counts of second-degree domestic battery. At issue before the Supreme Court was the circuit court's denial of Appellant's second petition for writ of habeas corpus, in which Appellant alleged that the Arkansas Department of Corrections illegally enhanced his sentence. The Supreme Court affirmed, holding that Appellant's sentences did not exceed the maximum penalty for the offenses to which he pleaded guilty, and therefore, the judgment was facially valid. View "Jefferson v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to proceed in forma pauperis in circuit court alleging that he was entitled to judicial review of a disciplinary action against him, holding that the circuit court did not err.Appellant, an inmate, assaulted and punched a correctional officer and had access to a cell phone. The Arkansas Department of Corrections found Appellant guilty of disciplinary violations and transferred him to the Varner Supermax Unit. Appellant filed a petition to proceed in forma paupers with a corresponding petition for judicial review, challenging the disciplinary procedures. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant had no basis to proceed in forma pauperis. View "Muntaqim v. Kelley" 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 Appellant failed to raise a claim that would warrant issuance of the writ.Appellant was convicted of capital murder and sentenced to life without parole. In his habeas petition, Appellant alleged that his conviction was void because the charging information did not reflect his full name, thus depriving the trial court of personal jurisdiction and subject-matter jurisdiction. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant's defective information claim was not cognizable in habeas proceedings. View "Rayford v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing and denying Appellant's pro se petition for writ of habeas corpus seeking relief from a Grant County capital murder conviction and a Ouachita county first-degree murder conviction, holding that there was no error.In his petition, Appellant contended that he was "charged and prosecuted on unconstitutionally vague, void, and invalid insufficient criminal informations" and raised claims regarding sufficiency of the evidence, trial error, ineffective assistance of counsel, and improper jury instructions. The circuit court denied the writ. The Supreme Court affirmed, holding that none of Appellant's claims merited issuance of the writ, and the circuit court did not clearly err by declining to issue the writ. View "Hill v. Kelley" on Justia Law

The Supreme Court denied Petitioner's pro se third petition and amended 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 convicted of first-degree murder and abuse of a corpse. The Supreme Court affirmed. In his third coram nobis petition Petitioner alleged, among other things, that the State violated Brady v. Maryland, 373 U.S. 83 (1963) by withholding the pretrial statement of a potential witness and the criminal history of a witness for the prosecution. The Supreme Court denied the petition, holding (1) Petitioner failed to establish a Brady violation; and (2) Petitioner's remaining claims did not provide grounds for issuance of the writ of error coram nobis. View "Williams v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of one count of rape and two counts of second-degree sexual assault, holding that the trial court did not abuse its discretion by denying Defendant's motion for continuance.Defendant was convicted of one count of rape and two counts of second-degree sexual assault. On appeal, Defendant argued that the trial court abused its discretion by denying his motion for continuance. The Supreme Court affirmed, holding that, under the totality of the circumstances, the trial court did not abuse its discretion in denying Defendant's motion for continuance. View "Beard v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's petition for a writ of habeas corpus, holding that the circuit court did not err.Defendant was convicted of first-degree murder and sentenced to life imprisonment. Defendant later filed a petition for a writ of habeas corpus, challenging the circuit court's jurisdiction to enter the sentencing order. The circuit court dismissed the habeas action for lack of probable cause. The Supreme Court affirmed, holding that the circuit court did not clearly err when it dismissed Defendant's habeas petition for a want of probable cause. View "Jackson v. Payne" on Justia Law