Justia Criminal Law Opinion Summaries
Articles Posted in Arkansas Supreme Court
Muntaqim v. Kelley
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
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Arkansas Supreme Court, Criminal Law
Rayford v. Payne
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
Posted in:
Arkansas Supreme Court, Criminal Law
Hill v. Kelley
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
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Arkansas Supreme Court, Criminal Law
Williams v. State
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
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Arkansas Supreme Court, Criminal Law
Beard v. State
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
Posted in:
Arkansas Supreme Court, Criminal Law
Jackson v. Payne
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
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Arkansas Supreme Court, Criminal Law
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
Posted in:
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
Posted in:
Arkansas Supreme Court, Criminal Law