Justia Criminal Law Opinion Summaries

The Supreme Court denied Petitioner's pro se second petition and amended second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claim did not establish a ground for issuance of the writ.Petitioner was convicted of first-degree murder, kidnapping, and aggravated assault. The Supreme Court affirmed. Petitioner later brought a pro se second petition and an amended second petition to reinvest jurisdiction jurisdiction in the trial court to consider a writ of error coram nobis, asserting that the State withheld evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petitions, holding that Petitioner's claims did not entitle him to relief. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second 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 two counts of the rape of his biological daughters. Petitioner later filed a petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis based on affidavits executed by his daughters that recanted their trial testimony. The Supreme Court denied the petition, holding that Petitioner failed to establish that the State violated Brady v. Maryland, 373 U.S. 83 (1963) and otherwise failed to establish sufficient grounds for issuance of the writ. View "White v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of coram nobis, holding that none of Petitioner's claims established grounds for the writ.Petitioner pleaded guilty to four counts of rape and nolo contendere to one count of rape. On appeal, Petitioner argued that the trial judge was biased at his resentencing hearing and should have recused himself or, alternatively, that the trial court should have permitted him to withdraw his guilty and nolo contendere pleas. The Supreme Court affirmed. In his coram nobis petition, Petitioner sought relief both for the alleged coercion of his pleas and for the trial judge's failure to recuse himself. The Supreme Court denied relief, holding that Petitioner's claims did not entitle him to coram nobis relief. View "Walls v. State" on Justia Law

The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law

The Supreme Court denied Petitioner's second 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 Petitioner failed to state a ground on which the writ could issue.Petitioner was convicted by a jury of first-degree murder and sentenced as a habitual offender to 600 months' imprisonment. The court of appeals affirmed. In his second petition for coram nobis relief, Petitioner argued that he was denied the effective assistance of counsel both at trial and on direct appeal and that the trial court erred in sentencing him as a habitual offender. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate a ground on which the writ could issue. View "Sims v. State" on Justia Law

The Supreme Court denied Petitioner's second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and seeking the appointment of postconviction counsel, holding that Petitioner failed to raise a cognizable claim for issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to a term of life imprisonment plus a term of 180 months. The Supreme Court affirmed. In the instant coram nobis petition, Petitioner argued that he was entitled to relief due to a coerced guilty plea, the failure of the prosecutor or his counsel to advise him of the spousal privilege in violation of Brady v. Maryland, 373 U.S. 83 (1963), and ineffective assistance of both trial counsel and postconviction counsel. The Supreme Court denied the writ and denied Petitioner's motion for appoint of counsel as moot, holding that Petitioner's claims were not cognizable in a coram nobis proceeding. View "Gordon v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's pro se petition to correct an illegal sentence, holding that the circuit court erred in denying the petition.Appellant pled guilty to one count each of aggravated residential burglary, aggravated robbery, kidnapping, and theft of property. Appellant was sentenced to an aggregate sentence of fifty-four years' imprisonment. Appellant filed a petition to correct an illegal sentence, alleging that his sentence exceeded the penalty for a Class D felony. In response, the circuit court entered an amended sentencing order nunc pro tunc. Appellant then filed a second petition challenging his sentence. The circuit court denied the petition on the basis that an amended order had been entered in the case. The Supreme Court reversed and remanded the case to correct the sentencing order, holding that the circuit court's nunc pro tunc failed to correct certain sentencing errors. View "Willingham v. State" on Justia Law

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 Petitioner failed to state a ground on which the writ could issue.Petitioner was convicted of capital murder and aggravated robbery and sentenced to death. The Supreme Court reversed the sentence and remanded for resentencing. On remand, Petitioner was sentenced to life imprisonment without parole. In the instant petition, Petitioner asked the Supreme Court to reinvest jurisdiction in the trial court so that he could raise the claim that he was denied effective assistance of counsel at trial and on direct appeal. The Supreme Court denied relief, holding that this Court declines to broaden the grounds for the writ to include claims of ineffective assistance of counsel. View "Daniels v. State" on Justia Law

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 to support his claim of an illegal sentence.Appellant was convicted of first-degree murder and sentenced to life imprisonment without parole. Appellant later filed a second pro se petition to correct illegal sentence, arguing that he did not qualify for a life sentence pursuant to Ark. Code Ann. 5-4-501(d). The circuit court denied the petition, determining that Appellant's life sentence was proper. The Supreme Court affirmed, holding that Appellant's sentence was clearly within the prescribed statutory range and was legal on its face. View "Coakley v. State" on Justia Law

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 present a cognizable claim for coram nobis relief.After a jury trial, Petitioner was found guilty of first-degree murder, aggravated residential burglary, attempted kidnapping, first-degree battery, and aggravated assault. In his coram nobis petition, Petitioner set forth five claims for relief, asserting that the claims constituted violations of his fundamental due process rights. The Supreme Court denied the petition, holding that the allegations raised by Petitioner did not set out facts that were extrinsic to the record and otherwise did not fall within the four categories recognized as grounds for issuance of the writ. View "Her v. State" on Justia Law