Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus, holding that the circuit court did not abuse its discretion in dismissing Appellant's petition.Appellant was convicted of rape and sentenced to two 120-month terms of imprisonment, to be served consecutively, for an aggregate term of 240 months' imprisonment. The court of appeals affirmed. Appellant later filed his petition for writ of habeas corpus, arguing that his consecutive sentences were illegal because the trial court abrogated the jury's recommendation for concurrent sentences. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's argument that the trial court lacked authority to impose consecutive sentences when the jury recommended concurrent sentences was without merit. View "Thompson v. Payne" 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 on which the writ could issue.Appellants was convicted of rape and fourth-degree sexual assault. The court of appeals affirmed the convictions and sentences. Appellant later brought this action raising five claims for habeas relief, including claims that he was tried in violation of his right to a speedy trial. The circuit court dismissed the habeas petition. The Supreme Court affirmed, holding that Appellant's claims fell outside the purview of habeas relief. View "Wade v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court resentencing Appellant to a term of life imprisonment, holding that the circuit court did not err in denying Appellant's resentencing motion, permanent-incorrigibility instruction, or witness testimony.Appellant was sixteen years old when he committed the crime that led to his conviction for capital murder. Appellant received a mandatory sentence of life imprisonment without the possibility of parole. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, Appellant's sentence was vacated. On remand, the circuit court resentenced Appellant to a sentence of life imprisonment. The Supreme Court affirmed, holding that the circuit court (1) did not err in denying Appellant's "Motion to Determine the Appropriate Procedure and Sentencing Range for Resentencing"; (2) did not abuse its discretion in refusing Appellant's permanent-incorrigibility jury instruction; and (3) did not err in sustaining the State's objection to a witness's testimony comparing Appellant's rehabilitation to that of other inmates. View "Elliott v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's successive pro se petition requesting or obtaining an authorization order for leave to amend and supplement records pursuant to Act 1780, codified at Ark. Code Ann. 16-112-201 to -208, holding that Appellant was not entitled to relief.Appellant was found guilty of rape, kidnapping, robbery, and other offenses. In the instant petition, Appellant made three claims for relief, including a claim seeking testing of evidence from his criminal case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not rebut the presumption against timeliness, failed to state facts that would entitle him to scientific testing, and raised successive claims. View "Hooper v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition for a writ of mandamus asking the Supreme Court to compel the circuit court to conduct a hearing on his petition for writ of habeas corpus filed under Ark. Code Ann. 16-112-201 to -208, holding that Petitioner failed to demonstrate that he was entitled to issuance of the writ.Petitioner pleaded guilty to first-degree murder and was sentenced to 240 months' imprisonment. Petitioner later filed a petition for writ of habeas corpus, arguing that the State withheld certain evidence held by the Arkansas State Crime Laboratory. Petitioner then brought this petition asking that the circuit court be compelled to conduct a hearing on his habeas petition. The Supreme Court denied the writ, noting that a hearing is not required on a habeas petition. View "Khalifa 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 none of Petitioner's claims established a ground for the writ.In his coram nobis petition, Petitioner argued that there were clerical errors, mistakes in the process of notice and pleadings, and events outside the courtroom that affected the reliability of the proceedings. The circuit court denied the writ. The Supreme Court affirmed, holding that Petitioner's application for coram relief failed to offer any factual substantiation for his claims, and therefore, Petitioner was not entitled to the writ. View "Carroll v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant failed to establish that he was entitled to issuance of the writ.Appellant was convicted of battery in the first degree and battery in the second degree and was sentenced to an aggregate term of 264 months' imprisonment. Appellant later filed a petition for writ of habeas corpus alleging that the trial court did not have jurisdiction over his criminal case. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant's assertions did not implicate the facial validity of the trial court's judgment or its jurisdiction. View "Harkuf v. Kelley" on Justia Law

The Supreme Court denied Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, holding that Petitioner failed to demonstrate in the petition that the writ should issue.In his petition, Petitioner argued that information was withheld in violation of Brady v. Maryland 373 U.S. 83 (1963), that the trial court lacked jurisdiction, and that there was no "bindover" at a preliminary hearing or grand jury. The Supreme Court denied the petition, holding (1) the majority of Petitioner's claims were an abuse of the writ; and (2) Petitioner's conclusory claims were not grounds for the writ. View "McClinton v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not err.In his petition, Petitioner argued that his sentence was illegal because the trial court lacked the authority to modify his sentence when it revoked his probation and that he was not afforded a preliminary hearing before he pled guilty to possession of a controlled substance. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the trial court had jurisdiction to modify Petitioner's sentence; and (2) Petitioner's remaining allegation constituted an untimely claim for postconviction relief. View "Ford v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that the trial court did not abuse its discretion in denying relief.Defendant pleaded guilty to three counts of first-degree assault, theft by receiving, and second-degree robbery. In his petition for a writ of error coram nobis Defendant argued that he was entitled to the writ pursuant to Brady v. Maryland, 373 U.S. 83 (1963). The trial court denied relief. The Supreme Court affirmed, holding that Defendant's multiple claims for error nobis relief failed because they were either conclusory, lacked supporting evidence, or did not fall within the purview of an error coram nobis proceeding. View "Everett v. State" on Justia Law