Justia Criminal Law Opinion Summaries

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

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

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

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

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

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

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