Justia Criminal Law Opinion Summaries

The Supreme Court reversed and vacated the judgment of the court of appeals affirming Defendant's conviction of first-degree assault and sentencing him to thirty days in jail, holding that Defendant failed to perfect his appeal from district court to circuit court, and therefore, the circuit court lacked jurisdiction over the appeal.On the thirty-ninth day from the district court judgment convicting him of first-degree assault, Defendant's attorney filed an affidavit with the circuit court stating that Defendant had filed a notice of appeal in the district court. The circuit court found Defendant guilty of second-degree assault. The court of appeals affirmed. On appeal, Defendant argued that he failed to perfect his appeal from the district court to the circuit court because he failed timely to file the record or a proper affidavit containing certain facts for the circuit court to acquire jurisdiction under Ark. R. Crim. P. 36(d). The Supreme Court agreed and reinstated the district court judgment, holding that an insufficient affidavit filed under rule 36(d) is a jurisdictional impairment to an appeal from a criminal conviction from district court to circuit court. View "Collins v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that Appellant failed to show that he was entitled to issuance of the writ.Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a petition for writ of habeas corpus, asserting that the trial court lacked jurisdiction to sentence him in excess of the alleged mandatory maximum determinate of forty years' imprisonment for first-degree murder. The circuit court denied the writ. The Supreme Court affirmed, holding that because Appellant was sentenced within the permitted statutory range for first-degree murder he failed to state a claim for issuance of the writ. View "McArty v. Payne" on Justia Law

In this criminal case, the Supreme Court held that Defendant was entitled to proceed with a belated appeal and that Defendant was indigent.Defendant was convicted of aggravated assault on a family member and was sentenced to 120 months' imprisonment. Due to conflicts between the allegations set forth in Defendant's motion for belated appeal and the affidavit filed by his trial counsel, the circuit court remanded the case for findings of fact with regard to whether Defendant had waived his right to an appeal and whether he was entitled to proceed as a pauper. After reviewing the record on remand the Supreme Court granted the motion for belated appeal and granted in forma pauperis status, holding that Defendant was entitled to proceed with a belated appeal and that he was indigent. View "Marek v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner failed to allege cognizable grounds for the issuance of a writ of error coram nobis.Petitioner was convicted of first-degree murder and sentenced to forty years in prison. The case was reversed, and therefore, the prosecutor added a habitual-offender charge to the information. After a retrial, the jury convicted Petitioner of first-degree murder and sentenced him to sixty years' imprisonment due to his habitual-offender status. Petitioner filed a petition for writ of error coram nobis, alleging prosecutorial misconduct and that his sentence was illegal. The Supreme Court denied the petition, holding that Petitioner's claims did not fall within the purview of coram nobis relief. View "King v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's petition for postconviction relief pursuant to Ark. R. Crim. P. 37, holding that the court did not err by denying the petition without a hearing.Appellant was convicted of murder in the first degree and sentenced to life imprisonment. In his Rule 37 petition, Appellant alleged that his trial counsel was ineffective for failing to request an instruction on second-degree murder. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err in summarily denying Appellant's Rule 37 petition. View "Riley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for a writ of mandamus with prejudice under Ark. R. Civ. P. 12(b)(6), holding that the circuit court did not abuse its discretion.Appellant was convicted of first degree murder and sentenced to life imprisonment. In 2010, Appellant submitted a request to the Arkansas State Crime Laboratory regarding DNA testing. The circuit court ordered the crime lab to release the information. When the file arrived at the prison, it was confiscated by prison officials based on their determination that it contained contraband. In 2019, Appellant filed a petition for writ of mandamus and complaint for conversion seeking to compel Appellees to release his crime lab file and monetary damages for conversion. The circuit court dismissed the case with prejudice and issued a strike. The Supreme Court affirmed, holding that the circuit court correctly dismissed Appellant's petition for writ of mandamus and complaint for conversion on the ground that Appellant had already obtained the crime lab file and that Appellant failed to state a claim upon which relief could be granted. View "Davis v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for a directed verdict, holding that the circuit court did not err in denying the motion.After a jury trial, Appellant was convicted of possession of methamphetamine and drug paraphernalia. On appeal, Appellant argued that the circuit court erred in denying her motion for a directed verdict because the State failed to prove that she possessed a "usable amount" of methamphetamine. The Supreme Court affirmed, holding that the circuit court properly denied Appellant's motion for a directed verdict. View "Kolb v. State" on Justia Law

The Supreme Court denied Petitioner's pro se motion to recall the mandate issued by the Supreme Court on direct appeal, his petition for a writ of habeas corpus, and his motion for joinder of claims, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment. The Supreme Court affirmed. In his motion to recall the mandate, Petitioner challenged the sufficiency of the evidence supporting his conviction and also brought a Brady claim. The Supreme Court denied relief, holding (1) Petitioner did not establish extraordinary circumstances sufficient to recall the mandate; (2) Petitioner must file his writ of habeas corpus in the circuit court; and (3) Petitioner did not establish that he was entitled to joinder of claims. View "Anderson 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 seeking scientific testing of evidence from his 1996 criminal case, holding that the circuit court did not err.In 1996, Appellant was convicted of capital murder and sentenced to life imprisonment. In 2012, Defendant filed a pro se petition for writ of habeas corpus pursuant to Act 1780, asserting that he was actually innocent of the murder and seeking DNA testing on a red shirt. The circuit court denied the petition. In 2020, Appellant filed a motion to file a second or successive petition for good cause seeking scientific testing pursuant o 16-112-201 through 16-112-208. The circuit court denied the petition as successive. The Supreme Court affirmed, holding that Appellant failed to establish that additional testing would significantly advance his claim of innocence. View "Hussey v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's petition to proceed in forma paupers in connection with a petition for a writ of habeas corpus, holding that the circuit court correctly determined that Appellant failed to state a colorable cause of action.Appellant was convicted of three counts of unlawful discharge of a vehicle and was sentenced as a habitual offender to seventy-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus seeking relief based on insufficient evidence supporting a firearm enhancement and an alleged double jeopardy violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the petition clearly failed to allege a colorable cause of action. View "Commons v. Kelley" on Justia Law