Justia Criminal Law Opinion Summaries
Articles Posted in Arkansas Supreme Court
Warner v. State
The Supreme Court affirmed the order of the circuit court convicting Defendant of raping six-year-old M.H. and sentencing him to an enhanced sentence of life imprisonment without parole, holding that there was no prejudicial error.On appeal, Defendant argued that substantial evidence did not support the conviction, the circuit court abused its discretion in admitting evidence of prior bad acts under the pedophile exception, and that the circuit court abused its discretion in admitting M.H.'s recorded statement. The Supreme Court affirmed, holding that there was no error on the part of the circuit court. View "Warner v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
McLaughlin v. State
The Supreme Court affirmed the order of the circuit court denying Appellant's pro se habeas petition filed under Ark. Code Ann. 16-112-201, holding that a writ of habeas corpus filed pursuant to section 16-112-210 could not issue on the bases set forth in the petition.Appellant was convicted of commercial burglary and first-degree criminal mischief. Appellant later brought this habeas petition, arguing that he was actually innocent in that the State failed to comply with a discovery request, his right to confront witnesses was violated, and that he was denied notice of certain witnesses to be called by the State. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the trial court correctly determined that Appellant's claims were not cognizable under Act 1780. View "McLaughlin v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Coakley v. State
The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief without holding an evidentiary hearing, holding that there was no error.Petitioner was convicted of first-degree murder and sentenced to life imprisonment without parole. In his petition for postconviction relief, Petitioner alleged that his counsel was ineffective for failing to develop the defense of provocation, among other things. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court's finding that Petitioner did not receive ineffective assistance of counsel was not clearly erroneous. View "Coakley v. State" on Justia Law
McKinney v. State
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow him to file a petition for writ of error coram nobis in his criminal case, holding that the claims raised by Petitioner did not establish a ground for the writ.Petitioner was found guilty by a jury of multiple drug-related offenses. After his convictions were affirmed Appellant brought this petition alleging that his attorney failed to represent him adequately and that his state of mind at trial amounted to "insanity." The Supreme Court denied the petition, holding that Petitioner's claims did not entitle him to relief. View "McKinney v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Chunestudy v. State
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 raise allegations that warranted coram nobis relief.Petitioner was found guilty of the rape of his minor daughter and sentenced to life imprisonment. In his petition for coram nobis relief, Petitioner argued that his daughter had recanted her trial testimony, his daughter perjured herself, and his trial counsel was ineffective. The Supreme Court denied the petition, holding that Petitioner failed to establish that he was entitled to the writ. View "Chunestudy v. State" on Justia Law
Brennan v. State
The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for postconviction relief, holding that there was no error.Appellant was convicted of murdering his wife. He later filed this petition, presenting five ineffective assistance of counsel claims. After an evidentiary hearing, the circuit court denied relief. On appeal, Appellant argued that the circuit court erred in failing to find that his trial counsel was ineffective because of a conflict of interest. The Supreme Court affirmed, holding that Appellant's argument was without merit, and the circuit court did not err in denying Appellant's petition. View "Brennan v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Williams v. Payne
The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's fourth pro se petition for a writ of habeas corpus, holding that Appellant failed to demonstrate that he was entitled to relief.In his petition, Appellant alleged that he was charged by information with three separate counts of rape under the same docket number but was wrongfully tried in three separate trials. Appellant further alleged that his rape convictions violated the prohibition against double jeopardy. The Supreme Court affirmed the dismissal of the habeas petition, holding that Appellant's claims were without merit. View "Williams v. Payne" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Wood v. State
The Supreme Court affirmed in part and reversed in part the judgment of the circuit court denying Appellant's motion to correct clerical errors in his sentencing order, holding that Appellant's sentencing order contained a clerical error.In his motion to correct clerical errors in his sentencing order, Appellant alleged that his sentencing order contained (1) an inaccurate criminal history score, (2) the wrong presumptive sentence, and (3) the incorrect date of his plea hearing. The circuit court denied the motion on the grounds that these issues were substantive rather than clerical. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) as to the first two alleged errors, the circuit court correctly denied Appellant's motion; and (2) the circuit court abused its discretion when it refused to enter an order nunc pro tunc correcting the third alleged clerical error. View "Wood v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Thompson v. Payne
The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted of six felony offenses, including aggravated residential burglary. In his habeas petition, Appellant alleged that his judgment of conviction was void because the trial judge failed to sign the sentencing order, in contravention of Arkansas Supreme Court Administrative Order No. 8. The circuit court dismissed the claim on the grounds that Appellant's sentencing order was electronically signed and filed in compliance with Administrative Order No. 21. The Supreme Court affirmed, holding that Appellant's claim constituted an assertion of trial error that was not cognizable in habeas proceedings. View "Thompson v. Payne" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Wells v. State
The Supreme Court denied Petitioner's petitions for writ of habeas corpus, to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, and to recall the mandate, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder in furtherance of aggravated robbery and sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed on appeal. Petitioner subsequently filed the petitions at issue on appeal, making several claims. The Supreme Court denied Petitioner's petitions for habeas relief, coram nobis relief, and to recall the mandate, holding that none of Petitioner's claims had merit. View "Wells v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law