Justia Criminal Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for coram nobis relief, holding that Petitioner failed to establish that the trial court abused its discretion and that the writ should have issued. Appellant pleaded guilty to first-degree battery and other offenses. Ten years later, Appellant filed a second pro se petition for writ of error coram nobis challenging the judgment. The trial court denied relief. The Supreme Court reversed and remanded, concluding that Appellant's Brady claim may have merit and that the trial court should hold an evidentiary hearing to consider the merits of the petition. On remand, after an evidentiary hearing, the trial court again denied relief. Appellant appealed, raising six claims of error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying the writ for coram nobis relief. View "Scott v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of capital murder, aggravated robbery, and a firearm enhancement, holding that there was no prejudicial error in the proceedings below. On appeal, Defendant argued that the circuit court erred in denying his motion to suppress his statements to police recorded in a police interrogation room and an alleged nonrecorded custodial statement made while police escorted him to a police car. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in rejecting Defendant's argument that the issuance of Miranda warnings was rendered ineffective; and (2) Defendant's remaining allegations of error were without merit. View "Pree v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of rape of a minor and sentence of life imprisonment without parole, holding that the circuit court did not err in denying Defendant's motions to dismiss and did not abuse its discretion in admitting certain evidence. Specifically, the Court held that the circuit court (1) did not err in denying Defendant's motion to dismiss for violating Defendant's right to a speedy trial because Defendant's speedy trial rights were not violated; (2) did not err in denying Defendant's motion to dismiss for prosecutorial delay because Defendant was not prejudiced by the delay of filing the charges; and (3) did not abuse its discretion in admitting an Arkansas Department of Correction "pen pack" and an Arkansas Court of Appeals opinion as evidence of prior convictions. View "Rayburn v. State" on Justia Law

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The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that there was no prejudicial error in the proceedings below. Specifically, the Court held that the trial court (1) did not err by denying Defendant's motion for directed verdict because there was sufficient evidence that Defendant acted with the purpose of causing the death of the victim; (2) did not abuse its discretion in allowing testimony over Defendant's objection involving prior incidents unrelated to the night of the charged murder; and (3) did not err in refusing Defendant's motion for a jury instruction on justification for manslaughter because the jury never considered manslaughter. View "Coakley v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of capital murder and first-degree battery, holding that the circuit court did not abuse its discretion in denying Defendant's motion for mistrial. On appeal, Defendant argued that a mistrial was warranted on the basis of a witness's statements during cross-examination. During trial, the witness accused defense counsel of threatening him and making other statements suggesting that defense counsel was trying to conceal evidence of Defendant's guilt. The Supreme Court affirmed, holding that the statement was not of such magnitude that it was an abuse of discretion for the circuit court to deny the motion for a mistrial, and the circuit court's admonition to the jury was sufficient to cure any possible prejudice stemming from the witness's remarks. View "Braud v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder in the first degree and battery in the first degree, holding that the circuit court did not err when it denied Appellant's request to instruct the jury as to the lesser-included offenses of murder in the second degree, extreme emotional distress manslaughter, and battery in the second degree. Specifically, the Court held (1) the circuit court did not abuse its discretion by refusing to give Appellant's proffered second-degree murder instruction because there was no rational basis for doing so; (2) the court did not abuse its discretion by deciding not to give the extreme emotional disturbance manslaughter instruction; and (3) the circuit court did not err when it refused to instruct the jury as to second-degree battery. View "Dixon v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree battery and possession of a firearm by certain persons but remanded with instructions to correct the sentencing order, holding that the circuit court did not abuse its discretion by limiting Defendant's cross-examination of the victim. Specifically, the Court held (1) the circuit court did not err in not allowing Defendant to ask six questions during the victim's cross-examination because Defendant failed to proffer the answers that he hoped to elicit on cross-examination and because the answers were not otherwise apparent from the contradictory context; (2) the circuit court did not err in denying Defendant's motion to dismiss for lack of a speedy trial; and (3) because the sentencing order misidentified an offense, the matter must be remanded for the court to correct the sentencing order. View "Perkins v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the dismissal of his pro se pleading wherein he requested scientific testing pursuant to Ark. Code Ann. 16-112-201, holding that Appellant's request for scientific testing was without merit. In 2000, Appellant pleaded guilty to first-degree sexual assault. Thereafter, Appellant filed several motions, including this motion for scientific testing. The trial court dismissed with prejudice Appellant's request for relief on the basis that Appellant had raised the same claims in his previous petitions and was not entitled to relief. The Supreme Court dismissed the appeal, holding that there was no need to consider Appellant's motions because his request for scientific testing was without merit, and the trial court did not clearly err when it rejected Appellant's claim for scientific testing as well as Appellant's other claims for postconviction relief. View "Leach v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the petition. Appellant pled guilty to one count of rape. In his coram nobis petition, Appellant alleged, among other things, that the guilty plea was coerced. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding (1) certain exhibits Appellant included in his brief to support his claim on appeal that were not included in Appellant's petition to the circuit court or otherwise contained in the record are removed from consideration; and (2) under the circumstances, the circuit court did not abuse its discretion in denying Appellant's petition. View "Kain v. State" on Justia Law

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The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of habeas corpus, holding that none of Appellant's claims were sufficient to demonstrate that the trial court lacked jurisdiction or that the judgment of conviction was invalid on its face. In 1991, Appellant was found guilty of capital murder and was sentenced to life imprisonment without parole. In 2018, Appellant filed his petition for a writ of habeas corpus, arguing, among other things, that new evidence had emerged exonerating him of the crime and that material evidence was withheld at his trial in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court found that the habeas petition was untimely and without merit. The Supreme Court affirmed, holding that Appellant failed to make a showing that the face of the judgment was invalid or to present evidence of probable cause to believe he was being illegally detained. View "McArthur v. State" on Justia Law