Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder, for which he was sentenced to life imprisonment, holding that the trial court did not abuse its discretion by not giving a jury instruction on second-degree murder, a lesser-included offense of first-degree murder.Defendant was charged with first-degree murder for fatally shooting his wife. The trial court denied Defendant's request to instruct the jury on second-degree murder, finding that there was no evidence that Defendant intended anything but to purposely take his wife's life. On appeal, Defendant argued that the trial court abused its discretion by not instructing the jury on second-degree murder. The Supreme Court affirmed, holding that there was no rational basis for giving the instruction, and therefore, the trial court did not err. View "Marshall v. State" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se civil rights complaint filed pursuant to the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108, in which he alleged that Arkansas Department of Correction (ADC) officials violated his constitutional rights, holding that the circuit court did not err in dismissing the complaint.Appellant sued Appellees in their official and individual capacities, alleging that they had violated his constitutional rights to free speech, free exercise of his religion, access to the court, due process, and equal protection. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that Appellees were immune from liability because Appellant failed to raise claims that demonstrated the deprivation of a constitutional right. View "Muntaqim v. Payne" 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 alleging that he was denied effective counsel prior to his criminal trial and that this violation of his Sixth Amendment right entitled him to coram nobis relief, holding that Petitioner was not entitled to relief.Petitioner was convicted of two counts of capital murder and one count of second-degree murder and sentenced to life imprisonment without parole on the capital murder charges. Petitioner later filed his coram nobis petition, raising claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner's allegations of ineffective assistance of counsel did not support issuance of the writ of error coram nobis. View "Hall v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. In his petition for writ of habeas corpus, Appellant appeared to challenge the validity of the statute pertaining to the offense of first-degree murder, the arrest warrant, the information, and the entry of the judgment of conviction. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant did not state grounds on which a writ of habeas corpus could issue. View "Fuller/Akbar v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for a writ of habeas corpus filed in the county of his incarceration, holding that Appellant failed to demonstrate that he was entitled to issuance of the writ.Appellant pleaded guilty to two counts of capital murder and was sentenced to life imprisonment without the possibility of parole. In his habeas corpus action, Appellant argued that because there was no record of the guilty proceedings to support what was contained in the judgment and commitment order, his judgment and commitment order was invalid on its face. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to state a basis for issuance of the writ. View "True v. Payne" on Justia Law

The Supreme Court denied Petitioner's petition to proceed in forma pauperis with respect to a petition for writ of certiorari, holding that Petitioner was not entitled to relief.Petitioner, proceeding pro se, submitted a complaint to the Judicial Discipline and Disability Commission concerning the circuit judge who presided at his criminal trial. Petitioner then tendered a petition for writ of certiorari to complete the record and to review the Commission's disposition of the complaint with the petition to proceed in forma pauperis seeking file the petition for writ of certiorari without remitting the required filing fee. The Supreme Court denied the petition, holding that where no fundamental right was involved, the filing fees did not violate due process. View "Burnside v. Arkansas Judicial Discipline & Disability Commission" on Justia Law

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