Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court convincing Defendant of first-degree murder and sentencing him to life imprisonment and a sentencing enhancement, holding that the circuit court did not err or abuse its discretion.A jury found Defendant guilty of the first-degree murder of Bianca Rainer. The Supreme Court affirmed the conviction, holding that the circuit court (1) did not err in refusing to suppress a detective's testimony about one of Defendant's custodial interviews that failed to record properly; and (2) did not abuse its discretion in admitting sixteen crime-scene and autopsy photographs of the victim over objections. View "Bennett v. State" 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 stated no ground on which the writ could issue.Appellant was convicted of second-degree murder and sentenced to 300 months' imprisonment with a firearm enhancement of 180 months. In his habeas petition, Appellant alleged that the judgment of conviction did not reflect that his sentence was enhanced as a habitual offender by requiring him to serve 100 percent of his sentence, and therefore, his sentence was illegal. The circuit court denied the petition. The Supreme Court affirmed, holding that because the judgment may be corrected at any time to reflect that Appellant was not eligible for parole, Appellant failed to demonstrate that he was entitled to habeas relief on the basis that his enhanced sentence was illegal. View "Jones v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without the possibility of parole, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the conviction; (2) the circuit court did not err in admitting evidence regarding Defendant's prior bad acts under Ark. R. Crim. P. 404(b) because the evidence had independent relevance and was not unduly prejudicial; and (3) the circuit court did not err in not allowing Defendant to question a detective regarding a prior inconsistent statement made by a witness. View "Atwood v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant did not state a ground for the writ.Appellant was found guilty of first-degree murder and sentenced as a habitual offender to 600 months' imprisonment. Appellant later filed a petition for writ of habeas corpus, asserting that the judgment was void because the information was signed by a deputy prosecutor rather than the prosecuting attorney. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant did not establish a basis for the writ because Appellant's claim was not cognizable in habeas proceedings. View "Sims v. Kelley" on Justia Law

The Supreme Court affirmed Defendant's conviction of three counts of rape, holding that there was no prejudicial error in the proceedings below.After a jury trial, Defendant was convicted of three counts of rape and sentenced to life imprisonment on each count. The Supreme Court affirmed, holding (1) the circuit court did not err when it did not grant Defendant's motion for a directed verdict; and (2) Defendant was not prejudiced and his right to a fair trial was not put in jeopardy when the circuit court allowed one of the victims to remain in the courtroom throughout the trial. View "Dominguez v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se motion to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that the motion was untimely.In 1990, Defendant was convicted of burglary and theft of property. Defendant was sentenced to forty years' imprisonment and thirty years' imprisonment, respectively. In his motion to correct an illegal sentence, Defendant argued that making the thirty-year sentence part consecutive and part concurrent was illegal. The trial court denied relief. The Supreme Court affirmed, holding (1) although Defendant characterized his claim as one alleging a facially invalid sentence, it was not, and therefore, section 16-90-111 did not apply; and (2) under Ark. R. Crim. P. 37.2(c), Defendant's motion was untimely. View "Prince v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's denial of Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that this Court lacked jurisdiction over the appeal.Appellant was convicted of capital murder and first-degree battery and sentenced to life imprisonment without parole. Appellant later filed a petition to correct an illegal sentence. The circuit court denied the petition, finding that it was untimely under Ark. R. Crim. P. 37.2. Appellant appealed. The Supreme Court affirmed, holding that Appellant did not proceed in the proper circuit court, and thus, the circuit court and the Supreme Court lacked jurisdiction to address his petition. View "Grant v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying and dismissing Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to issue the writ.Appellant pleaded guilty to robbery and first-degree battery. Appellant later filed a petition for a writ of error coram nobis, asserting that his attorney and the prosecutor conducted a scheme to deceive him into entering a guilty plea. The trial court denied relief. The Supreme Court affirmed, holding that Appellant's conclusory claims in support of the allegation were not a ground for the writ and that Appellant did not meet his burden of establishing that the plea was the result of fear, duress, or threats of mob violence. View "Addison v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying relief.Defendant pleaded guilty to sexual abuse and was sentenced to 360 months' imprisonment. Defendant later filed a petition for a writ of error coram nobis alleging that the prosecutor withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court denied relief. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that there is a reasonable probability that the judgment of conviction would not have been rendered or would have been prevented had the allegedly withheld information been disclosed; and (2) the circuit court did not err by not conducting an evidentiary hearing on the petition. View "Wood v. State" on Justia Law

The Supreme Court granted in part and denied in part Petitioner's pro se petition for writ of mandamus in which Petitioner contended that circuit court judge Dion Wilson failed to act on a petition for a previously filed writ of mandamus and amended petition for writ of mandamus, holding that Petitioner was entitled to rulings on the petitions but was not entitled to rulings granting the mandamus petitions "outright."Specifically, the Supreme Court held (1) because the circuit court had not acted on the petitions, Petitioner was entitled to an order disposing of the matter underlying the mandamus petitions; but (2) Petitioner was not entitled to relief on his request that the underlying mandamus petitions be granted outright and that he be granted a hearing. View "Rodgers v. State" on Justia Law