Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the denial of Appellant's pro se petition for writ of habeas corpus, holding that there were no grounds stated on which a writ of habeas corpus could be issued.Defendant was convicted of two counts of negligent homicide, leaving the scene of an accident involving injury or death, driving on a suspended license, and driving while intoxicated. Defendant filed a petition for a writ of habeas corpus, raising several allegations. The Supreme Court found that Defendant's allegations did not establish probable cause for issuance of the writ. The Supreme Court affirmed, holding that Defendant was not entitled to issuance of the writ. View "Rabion v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, holding that the trial court did not err when it did not bring jurors into open court after they posed a question during deliberations.Defendant was convicted of capital murder and sentenced to life imprisonment without parole. For his sole point on appeal, Defendant argued that the trial court erred when it did not bring the jurors into open court after they posed a question during deliberations. The State conceded that the court violated Ark. Code Ann. 16-89-125(e) by not bringing the jury into open court when it asked a question. The Supreme Court held that because there was no risk of misinformation being communicated to the jury the State met its burden of overcoming the presumption of prejudice. View "Combs v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant'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 pursuant to North Carolina v. Alford, 400 U.S. 25 (1977), to second-degree sexual assault. In his coram nobis petition, Defendant argued that his guilty plea was coerced. The trial court denied issuance of the writ. The Supreme Court denied relief, holding that the trial court did not clearly err when it gave greater weight to the testimony of Defendant's counsel and did not abuse its discretion when it denied Defendant's petition for coram nobis relief. View "Flow v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that no prejudicial error occurred during the proceedings below.Defendant was convicted of capital murder and aggravated assault. On appeal, Defendant argued that the circuit court erred in denying his motion for directed verdict and in admitting autopsy photographs after he offered to stipulate the cause of death. The Supreme Court affirmed, holding (1) substantial evidence supported Defendant's conviction; and (2) the circuit court did not abuse its discretion by admitting the autopsy photographs to aid the jury in understanding the nature and degree of the injuries the victims sustained and corroborated witness testimony. The Supreme Court remanded the case to the circuit court with directions to correct two clerical errors found in the sentencing order. View "Collins v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment to Professional Background Screening Association, Inc. (PBSA) on PBSA's claim pursuant to the Arkansas Freedom of Information Act (FOIA) and partial summary judgment to Jennifer Jones, the Clerk of the District Court of Benton County, Arkansas, Bentonville Division, holding that the circuit court did not err.PBSA, a nonprofit trade association, filed a complaint against Jones alleging that Jones erred in applying Arkansas Supreme Court Administrative Order Number 19 to PBSA members who request court records to perform background checks in a manner that violated their right to access court records and, instead, PBSA members' requests for court records are governed by the Arkansas Freedom of Information Act. The circuit court granted partial summary judgment in favor of PBSA on its FOIA claim and granted Jones's motion for summary judgment on PBSA's claims alleging that Order 19, as applied by Jones, violated PBSA members' right to access court records under the First Amendment and/or federal common law. The Supreme Court affirmed, holding that the circuit court did not err. View "Jones v. Professional Background Screening Ass'n" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.Appellant was convicted of four counts of computer exploitation of a child in the first degree and twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. Appellant later filed a petition for a writ of corpus alleging that his convictions were invalid for several reasons. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish that the circuit court erred by denying habeas relief. View "Rea v. Kelley" 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 none of Appellant's allegations were cognizable in a habeas proceeding.Appellant entered a guilty plea to three counts of first-degree terroristic threatening and was sentenced to 120 months in prison. In his habeas petition, Appellant argued that there was insufficient evidence to support the convictions, his arrest was illegal, and his guilty plea was rendered involuntary by flaws in the plea proceedings. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's habeas claim was properly denied. View "Lewis v. Payne" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to grant the relief sought.In two separate criminal cases, Appellant pled guilty to multiple charges of commercial burglary. In his coram nobis petition, Appellant argued that his guilty plea was coerced when two police officers threatened to charge his wife. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant's claim of coercion was unsubstantiated and that, even if it were substantiated, Appellant failed to pursue the claim with diligence. View "Lewis 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 in the county where Appellant was incarcerated pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of aggravated robbery, first-degree battery, and attempted rape and was sentenced as a habitual offender. In his habeas corpus petition, Appellant asserted that he was deprived of his right to an appeal due to his counsel's procedural error, that his conviction for attempted rape was not supported by sufficient evidence, and that his parole eligibility date was miscalculated. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. View "Hall v. State" on Justia Law

The Supreme Court affirmed the trial court's denial of Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying relief.Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In this habeas petition, Appellant alleged that the arrest warrant was invalid, the trial court lacked the authority to amend the information, and the sentencing order was void. The circuit court dismissed the habeas corpus petition on the merits. The Supreme Court affirmed, holding (1) because Appellant's first two claims had been raised and rejected before and Appellant failed to bring new facts to enliven the claims, that failure constituted an abuse of the writ; and (2) the arguments Appellant made in support of his third argument lacked merit. View "Watson v. Payne" on Justia Law