Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's claim for habeas relief on the grounds that Petitioner's allegations should have been raised at trial or in a timely petition under Ark. R. Crim. P. 37.1, holding that Petitioner failed to raise a claim for issuance of the writ.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner later filed his habeas corpus petition, arguing that his conviction was void because he was tried by an eleven-member jury. The circuit court dismissed the action. The Supreme Court affirmed, holding that Petitioner's claim constituted a due process claim that was not cognizable in a habeas proceeding and should have been raised on direct appeal or in a petition for postconviction relief. View "Phillips v. Culpepper" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellant entered a plea of nolo contenders to manslaughter and false imprisonment. Appellant was sentenced as a habitual offender to twenty years' imprisonment for manslaughter and ten years' suspended imposition of sentence for false imprisonment. Appellant later filed a habeas petition contending that the felony information in his case was insufficient because it did not charge him with being a habitual offender. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that the trial court lacked jurisdiction in his case. View "Johnson v. Payne" on Justia Law

The Supreme Court denied Petitioner's pro se fourth petition to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis, holding that Petitioner failed to allege sufficient grounds for the issuance of the writ.Petitioner was convicted of rape and theft of a van. In the coram nobis petition at issue, Petitioner alleged that the prosecutor withheld DNA evidence derived from a vaginal swab taken from the victim and that the DNA evidence was material. Petitioner also filed two motions in connection with the coram nobis petition. The Supreme Court denied the petition, which rendered moot the motions, holding that Petitioner was not entitled to relief. View "Makkali 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 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

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

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

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

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

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

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