Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that Appellant failed to allege that his sentence was facially illegal or that the trial court lacked subject matter jurisdiction.Appellant pleaded guilty to four counts of first-degree sexual assault and was sentenced to 336 months' imprisonment. Appellant later filed a petition to correct an illegal sentence, but none of Appellant's claims asserted that his sentence was facially illegal or that the circuit court lacked subject-matter jurisdiction. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied Appellant's petition to correct an illegal sentence. View "Hayes v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief under Ark. R. Crim. P. 37.1 without holding an evidentiary hearing, holding that the petition and record conclusively showed that Defendant was not entitled to relief.Defendant was convicted of raping his young daughter and sentenced as a habitual offender to life imprisonment without parole. Defendant later filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel and other claims for relief. The circuit court denied the petition, concluding that Defendant's claims were without merit. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the petition. View "Rayburn v. State" on Justia Law

The Supreme Court affirmed an order of the circuit court denying Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the circuit court abused its discretion in declining to grant the relief sought.In his petition for writ of error coram nobis Appellant alleged that the State withheld exculpatory evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). After a hearing, the circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Appellant's claims and denying his pro se petition for writ of error coram nobis. View "Myers v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant to life imprisonment after a resentencing hearing, holding that no prejudicial error occurred.Defendant, who was seventeen when he committed the offenses, was convicted of capital murder and aggravated robbery and sentenced to life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Defendant's sentence was vacated and a resentencing hearing was held. The trial court subsequently imposed a life sentence. The Supreme Court affirmed, holding that the trial court did not err or abuse its discretion. View "Ventry v. State" on Justia Law

The Supreme Court affirmed the decision 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 state a basis for issuance of the writ.Appellant was convicted of aggravated robbery and sentenced to life imprisonment as a habitual offender. Appellant later filed this petition for a writ of habeas corpus, arguing that the trial court's failure to hold a hearing regarding whether he should have been charged as an adult violated his due process rights and rendered his sentence invalid. The Supreme Court affirmed the circuit court's dismissal of the petition, holding that Appellant was not entitled to relief. View "Osborn v. Payne" on Justia Law

The Supreme Court affirmed the conclusions of the trial court denying Petitioner's petition and amended petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err or abuse its discretion.Petitioner was convicted of rape and second-degree sexual assault. In his petition for postconviction relief, Petitioner claimed that his trial attorneys failed to render effective assistance. The trial court addressed some but not all claims brought by Petitioner and found them to be within merit under Strickland v. Washington, 466 U.S. 668 (1984). The Supreme Court affirmed, holding (1) Petitioner waived appellate review of most of his claims; and (2) as to the remaining claims, the trial court did not err in finding them to be without merit. View "Lowery 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 and for clarification of certain dates in which Petitioner claimed that the State committed a Brady violation and that Petitioner was being denied due process of law and being subjected to cruel and unusual punishment, holding that none of Petitioner's claims established a ground for the writ.Petitioner was convicted of possession of drug paraphernalia with intent to manufacture methamphetamine and possession of a controlled substance (methamphetamine) and sentenced to 240 months' imprisonment. After an unsuccessful appeal, Petitioner brought this petition. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate that he was entitled to coram nobis relief. View "Ashley v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant failed to demonstrate entitlement to issuance of the writ.Appellant pleaded guilty to capital murder and kidnapping and was sentenced to life imprisonment without parole. Appellant later filed a petition for writ of habeas corpus, alleging that the trial court lacked jurisdiction to convict him, that he was searched and arrested illegally, and that his trial counsel was ineffective. The circuit court denied and dismissed the petition, concluding that Appellant's claims were not cognizable in habeas proceedings. View "Wolfe v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's postconviction petition filed under Ark. R. Crim. P. 37, holding that the circuit court did not err.Defendant was convicted of four counts of rape and one count of terroristic threatening. The Supreme Court affirmed. Thereafter, Defendant filed amended petition under Rule 37 alleging six grounds for relief. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in finding that trial counsel provided constitutionally effective assistance of counsel; and (2) the circuit court did not abuse its discretion in striking the testimony of Defendant's expert witness. View "Joyner v. State" on Justia Law

The Supreme Court dismissed this interlocutory appeal brought by the State pursuant to Ark. R. App. P.-Crim. 3 arguing that the circuit court erred in granting Defendant's motion to suppress medical records obtained through a prosecutor's subpoena, holding that the appeal was not a proper State appeal under Rule 3.The State charged Defendant with one count of negligent homicide after he rear-ended a vehicle, causing an accident that killed a minor. Defendant filed a motion to suppress the results of a urine sample collected at the hospital and medical records that were obtained by the State, which included the results of a blood test taken as part of Defendant's medical treatment. The circuit court granted the motion to suppress, and the State appealed. The Supreme Court dismissed the appeal, holding that the State did not have a proper basis to appeal. View "State v. Kirchner" on Justia Law