Justia Criminal Law Opinion Summaries

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's claim was not cognizable in habeas proceedings.In three separate cases, Appellant was convicted of three counts of aggravated robbery, two counts of a terroristic act, rape and aggravated robbery. Appellant's current habeas petition challenged all three convictions based on defective informations. The circuit court denied habeas relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claim for habeas relief as not cognizable. View "Benson v. Payne" on Justia Law

The Supreme Court affirmed the circuit court's order denying 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 committing a terroristic act. The Supreme Court affirmed. In his habeas petition, Appellant argued that the first-degree murder conviction and the conviction for a terroristic act constituted multiple punishments for a single action, in violation of double jeopardy protections. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant did not meet his burden of establishing that his double jeopardy claim was cognizable in a proceeding for a writ of habeas corpus. View "Starling v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court's denial of Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that Petitioner did not allege or demonstrate in this appeal that the imposed sentences were facially illegal.Petitioner challenged the amended sentence imposed for theft of property, asserting that the property stolen did not exceed $1,000, and therefore, his sentence was excessive. The circuit court summarily denied the petition. The Supreme Court affirmed, holding that Petitioner's petition to correct the sentences imposed in the amended sentencing order was untimely and did not include a valid claim for relief under section 16-90-111. View "Green v. State" on Justia Law

The Supreme Court denied Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claim has been raised in previous petitions and rejected by this Court.Petitioner was convicted of residential burglary, first-degree battery, and aggravated robbery and sentenced to an aggregate term of 480 months' imprisonment. In his third coram nobis petition, Petitioner reasserted his claim that he was deprived of counsel during his criminal trial because his trial counsel's license was suspended at the time of trial. The Supreme Court denied the petition, holding that the petition was an abuse of the writ. View "Washington v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder, for which he was sentenced to life imprisonment, holding that there was no prejudicial error in the proceedings below.The victim in this case died two hours after Defendant threw a cup of gasoline on him, lit a cigarette lighter, and ignited the victim's upper torso, arms, and face. On appeal, Defendant argued that there was insufficient evidence to support the first-degree murder conviction because he did not "cause" the victim's death. The Supreme Court disagreed, holding that the State presented sufficient evidence for the jury to conclude that Defendant caused the victim's death. View "Brown v. State" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the circuit court failed to make specific written findings of fact and conclusions of law on Appellant's last claim of ineffective assistance of counsel.Appellant was convicted of capital murder and sentenced to death. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, among other things, that his trial counsel was ineffective for failing adequately to investigate and challenge aggravation factors. The circuit court denied the petition. The Supreme Court reversed, holding that the circuit court failed to make findings of fact or conclusions of law addressing Appellant's last claim of ineffective assistance of counsel, as required under Rule 37.5(i). The Court remanded the case to the circuit court for entry of an order that complies with Rule 37.5(i). View "Gay v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction fo multiple drug crimes, holding that the circuit court did not err or abuse its discretion.On appeal, Defendant argued that there was insufficient evidence to support the convictions because the State's expert identified the drugs only via visual inspection and that the court erred in denying his motion to suppress because the search warrant was defective. The Supreme Court affirmed, holding (1) sufficient evidence supported both possession convictions; (2) the incorrect information on the warrant was mitigated by the fact that the officers executing the warrant knew which home was to be searched; and (3) the circuit court did not abuse its discretion when it limited certain evidence. View "Kellensworth v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of first degree murder and sentence of life imprisonment, holding that the per se improper political activity of the prosecutor campaigning for a judicial position during trial so infected the integrity of the proceeding as to warrant a new trial.This was Defendant's third trial for the murder of Jesse Hamilton. The first conviction was reversed on appeal, and a mistrial occurred on remand. After a third trial, Defendant was again convicted of murder. Prosecutor Stephanie Barrett prosecuted the case, and at the time of the third trial, Barrett was campaigning for a position in the Arkansas Court of Appeals. Defendant moved for a mistrial based on an appearance of impropriety. The motion was denied. Following his conviction, Defendant appealed the circuit court's decisions related to the prosecutor's campaigning and solicitation of signatures at the courthouse. The Supreme Court reversed, holding that the prosecutor's improper political activity and the failure of the trial court to resolve the situation so compromised the integrity of Defendant's trial as to warrant a new trial. The Court remanded the case for a fourth trial. View "Stanton v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court dismissing charges against Defendant based on a speedy-trial violation, holding that the circuit court erred in finding that the necessary conditions for implementation of the Interstate Agreement on Detainers (IAD), Ark. Code Ann. 16-95-101, had been met.Defendant filed a motion to dismiss all pending criminal actions against him arguing that he had not been brought to trial within 180 days of the date his notice and request for final disposition were filed, in violation of the IAD's speedy-trial provision. The circuit court granted the motion. The Supreme Court reversed, holding (1) a detainer, unless based upon an untried indictment, information or complaint, will not trigger application of the IAD; and (2) the circuit court erred in finding that the IAD applied in Defendant's case. View "State v. Higginbotham" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a ground on which the writ could issue.Appellant was convicted of second degree murder and sentenced as a habitual offender to eighty years' imprisonment. The court of appeals affirmed. In his petition for writ of habeas corpus Appellant alleged that the trial court lacked jurisdiction to enter the judgment sentencing him as a habitual offender and that the judgment was illegal on its face because he was convicted under a habitual offender statute that was not in effect when he committed the murder. The Supreme Court affirmed, holding that Appellant's allegations were not cognizable in habeas proceedings. View "Rainer v. Director, Arkansas Department of Correction" on Justia Law