Justia Criminal Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to correct an illegal sentence, filed pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to allege facts that supported his claim of an illegal sentence.On appeal, Appellant argued (1) the circuit court lacked authority to impose the sentence; (2) the special prosecutor was not authorized to sign the felony information; (3) the felony information was invalid because it was not signed and did not have an official seal from the clerk; and (4) the jury verdict forms were ambiguous. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err by denying Appellant's requested relief. View "Rea v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentence was illegal on its face.Appellant was convicted of rape and sentenced to twenty-five years' imprisonment. Appellant later brought his petition to correct an illegal sentence, arguing that the evidence adduced at trial established that he was guilty of fourth-degree sexual assault. The trial court denied the petition. The Supreme Court affirmed, holding that because Appellant's challenge was to the sufficiency of the evidence, the circuit court did not clearly error when it rejected Appellant's claim for relief. View "Clark v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the judgment of the circuit court denying Defendant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that, as to the suspended imposition of sentences for two counts of first-degree endangerment of a minor, both were statutorily unauthorized and facially illegal.Defendant pleaded guilty to and was convicted of five felony counts and sentenced as a habitual offender. In his petition to correct an illegal sentence, Defendant argued that his sentences were illegal for several reasons. The circuit court denied the petition, concluding that Defendant's claims were untimely and improper. The Supreme Court (1) affirmed the circuit court's finding that Defendant's claim constitute an untimely petition challenging the manner in which his sentences were imposed; and (2) reversed and remanded with regard to the suspended imposition of sentences for the endangerment of a minor counts because the suspensions were imposed consecutively, one exceeded the statutory maximum for a Class D felony, and both were statutorily unauthorized and facially illegal. View "Muhammad v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition for relief from an illegal sentence under Ark. Code Ann. 16-90-111, holding that the circuit court did not err.Defendant pleaded guilty to first-degree murder and was sentenced as a habitual offender to fifty-three years' imprisonment. Defendant later filed a petition for relief from an illegal sentence alleging that his sentence was illegal on four grounds. The circuit court denied the petition, concluding (1) Defendant's sentence was not facially illegal in that it fell below the statutory maximum, and (2) the remaining allegations were untimely and otherwise without factual support. The Supreme Court affirmed, holding (1) Defendant sentence was within the maximum prescribed sentence and was legal on its face; and (2) Defendant's remaining allegations were unavailing. View "Smith v. State" on Justia Law

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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 that the State violated Brady v. Maryland, 373 U.S. 83 (1963).Appellant was convicted of second-degree battery and being a felon in possession of a firearm and sentenced as a habitual offender to an aggregate term of 660 months' imprisonment. The court of appeals affirmed. In his petition for writ of error coram nobis Appellant alleged that the State committed a Brady violation by withholding the criminal history of two primary witnesses at his trial. The Supreme Court denied the petition, holding that Appellant failed to demonstrate the prejudice prong of a Brady claim. View "Russell v. State" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the denial of his petition for writ of mandamus/prohibition, holding that Appellant filed his petition in the wrong county.A Phillips County jury convicted Appellant of sexual assault in he first degree. The court of appeals affirmed. Appellant later filed this petition in Phillips County for writ of mandamus/prohibition, alleging that Appellees miscalculated his parole eligibility by requiring that he serve 100 percent of his sentence pursuant to Ark. Code Ann. 16-93-609(b)(1). The circuit court denied the petition. The Supreme Court affirmed, holding that, where neither the director nor keeper of the records of the Arkansas Department of Correction was located in Phillips County, Appellant was not entitled to relief in the Phillips County Circuit Court. View "Jenkins v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for a writ of habeas corpus, holding that Appellant's claims fell outside the purview of habeas relief.Appellant was convicted of capital murder and kidnapping and sentenced to life imprisonment without parole. The Supreme Court affirmed on direct appeal. Appellant later filed a pro se petition for writ of habeas corpus, alleging that he was actually innocent and that insufficient evidence supported his capital murder conviction. The circuit court denied the petition for writ of habeas corpus. The Supreme Court affirmed, holding that where Appellant was not challenging the facial validity of his life sentence or the jurisdiction of the circuit court to enter the judgment of conviction, Appellant was not entitled to habeas relief. View "Peeler v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus, holding that the circuit court did not abuse its discretion in dismissing Appellant's petition.Appellant was convicted of rape and sentenced to two 120-month terms of imprisonment, to be served consecutively, for an aggregate term of 240 months' imprisonment. The court of appeals affirmed. Appellant later filed his petition for writ of habeas corpus, arguing that his consecutive sentences were illegal because the trial court abrogated the jury's recommendation for concurrent sentences. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's argument that the trial court lacked authority to impose consecutive sentences when the jury recommended concurrent sentences was without merit. View "Thompson v. Payne" on Justia Law

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The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellants was convicted of rape and fourth-degree sexual assault. The court of appeals affirmed the convictions and sentences. Appellant later brought this action raising five claims for habeas relief, including claims that he was tried in violation of his right to a speedy trial. The circuit court dismissed the habeas petition. The Supreme Court affirmed, holding that Appellant's claims fell outside the purview of habeas relief. View "Wade v. Payne" on Justia Law

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The Supreme Court affirmed the order of the circuit court resentencing Appellant to a term of life imprisonment, holding that the circuit court did not err in denying Appellant's resentencing motion, permanent-incorrigibility instruction, or witness testimony.Appellant was sixteen years old when he committed the crime that led to his conviction for capital murder. Appellant received a mandatory sentence of life imprisonment without the possibility of parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant's sentence was vacated. On remand, the circuit court resentenced Appellant to a sentence of life imprisonment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Appellant's "Motion to Determine the Appropriate Procedure and Sentencing Range for Resentencing"; (2) did not abuse its discretion in refusing Appellant's permanent-incorrigibility jury instruction; and (3) did not err in sustaining the State's objection to a witness's testimony comparing Appellant's rehabilitation to that of other inmates. View "Elliott v. State" on Justia Law