Justia Criminal Law Opinion Summaries

The Supreme Court affirmed Defendant's conviction of second-degree sexual assault and sentence of sixty months' imprisonment, holding that the victim's therapy records were protected from disclosure by the absolute psychotherapist-patient privilege in Ark. R. Evid. 503.On appeal, the court of appeals determined (1) the Arkansas privilege law did not absolutely shield the victim's therapy records, and the circuit court should have conducted an in camera review for favorable Brady evidence; and (2) the records did not satisfy Brady's materiality requirement. The Supreme Court vacated the court of appeals' judgment and affirmed Defendant's conviction, holding (1) the therapy records and communications were privileged under Rule 503; and (2) Defendant was not constitutionally entitled to disclosure of the privileged records. View "Vaughn v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's three pro se petitions for a writ of error coram nobis, holding that the circuit court did not err by not granting relief.Appellant pled guilty to four counts of first-degree sexual assault. Appellant later filed three separate petitions for error coram nobis relief. The trial court denied all three petitions. The Supreme Court affirmed, holding that even if Appellant's allegations were considered to be true, Appellant did not establish that there was a reasonable probability that the allegations would have changed the result of the proceedings. View "Hayes v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder, first-degree escape, and employment a firearm to commit the murder, holding that there was no prejudicial error.Specifically, the Supreme Court held (1) the circuit court did not err by denying Defendant's motion for directed verdict on the first-degree-murder charge; (2) Defendant was not denied assistance of counsel; (3) the circuit court did not abuse its discretion by not instructing the jury on the lesser-included offenses of second-degree murder and manslaughter; and (4) the circuit court did not abuse its discretion in excluding certain text messages that were purportedly sent to Defendant by the victim. View "Armstrong v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to establish grounds for the writ.Petitioner was convicted of capital murder and sentenced to death. His death sentence was later modified to a term of life imprisonment without parole. In the instant coram nobis petition, Petitioner asserted that the trial court was required to appoint two attorneys to appoint two attorneys to serve as counsel during his trial and that the single attorney appointed to represent him was ineffective. The Supreme Court denied the petition, holding that Petitioner did not establish grounds for the writ. View "Wooten v. State" on Justia Law

The Supreme Court affirmed the circuit court's judgment denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a ground for the writ.Following a bench trial, Appellant was convicted of aggravated robbery, theft of property, and employment of a firearm to commit aggravated robbery. The court of appeals affirmed. Appellant later filed a habeas petition alleging that his conviction was invalid because he was denied his right to a speedy trial. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that the petition was correctly denied and dismissed because speedy trial claims do not state a viable habeas claim. View "Talley v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment plus fifteen years for a firearm enhancement, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the circuit court did not err by (1) admitting the victim's hearsay statements after finding they went to the victim's state of mind at the time of her death; (2) admitting an in-court identification; and (3) admitting evidence of Defendant's efforts to flee law enforcement in Texas and West Virginia as independently relevant to demonstrate a consciousness of guilt. View "Dorsey v. State" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of certiorari and his alternative request to recall the mandate, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. In his petition for certiorari and motion to recall the mandate, Petitioner argued that there was a defect in his criminal proceedings in that the trial judge failed to recuse himself in a posttrial matter, invalidating the judgment of conviction. The Supreme Court denied relief, holding that Petitioner's first argument was unavailing and that Petitioner did not establish the criteria that would establish extraordinary circumstances sufficient to recall the mandate. View "Rayford v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions but reversed the amount of assessed costs, holding that the court costs billed to Defendant were excessive according to statute and that no other prejudicial error was present in this case.Defendant was convicted of first-degree murder, aggravated assault, and first-degree terroristic threatening. Defendant was sentenced to life imprisonment plus a fifteen-year firearm enhancement for his murder conviction. On appeal, Defendant challenged the sufficiency of the evidence as to each conviction. The Supreme Court affirmed the convictions but reversed the amount of assessed court costs, holding (1) under statute, the court costs billed to Defendant should have been $150 instead of $165; and (2) there was no prejudicial error as to Defendant's remaining allegations of error. View "Hayes v. State" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise claims that are cognizable in coram nobis proceedings.Petitioner was found guilty of two counts of rape. In his coram nobis petition, Petitioner claimed that as a result of his mental defect he was incompetent to stand trial. The Supreme Court denied relief, holding that because Petitioner made no assertion that there was any evidence of his incompetence regarding a mental disease or defect extrinsic to the record, hidden from the defense, or unknown at the time of trial, Petitioner fell short of meeting his burden of disclosing a fact extrinsic to the record on which a writ of error coram nobis should issue. View "Smith v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of habeas corpus and petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err.Appellant, an inmate, pleaded guilty to failure to report and the related revocation in several felony cases. Appellant filed numerous pleadings, all of which the trial court denied. Appellant appealed the trial court's denial of habeas corpus and Rule 37.1 relief. The Supreme Court affirmed, holding (1) the circuit court lacked jurisdiction over Appellant's habeas corpus petition; and (2) because Appellant did not file his petition within the time limit set by Rule 37.1, the trial court properly denied postconviction relief. View "Taylor v. State" on Justia Law