Justia Criminal Law Opinion Summaries

The Supreme Court denied Petitioner's petition seeking permission to file a writ of error coram nobis in the trial court, holding that Petitioner failed to demonstrate that he was entitled to coram nobis relief.Petitioner was convicted of two counts of felony murder and sentenced to life without parole. The judgment was affirmed on appeal. In his coram nobis petition, Petitioner raised four claims that were not cognizable in a proceeding for writ of error coram nobis. Petitioner also asserted a Brady violation, but the Court held that the Brady allegation alone was not a sufficient basis for error coram nobis relief. Petitioner also requested an attorney. The Supreme Court held that because Petitioner did not make a meritorious claim, he was not entitled to appointment of counsel. View "Linell v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court dismissing Appellant's petition for writ of habeas corpus and denied the motions subsequently filed by Appellant to amend his reply brief, holding that the circuit court did not err.In his petition, Appellant alleged (1) the judgment and commitment order was illegal on its face because it was signed by a judge that did not preside at his trial and lacked jurisdiction to enter the judgment, (2) the trial court exceeded its jurisdiction when it admitted certain evidence, and (3) the judge lacked jurisdiction because he failed to recuse himself. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims were either without merit or were not cognizable in a habeas proceeding; and (2) the circuit court was not required to appoint counsel and hold a hearing on the petition. View "Jackson v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err when it dismissed the petition without holding a hearing.In 2003, Appellant was convicted of second-degree murder and sentenced to eighty years' imprisonment. In 2019, Appellant filed a petition for writ of habeas corpus, alleging that the trial court did not have jurisdiction to convict him of second-degree murder when he was charged with first-degree murder and that there was no rational basis to support a conviction for the lesser-included offense. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding (1) the circuit court correctly dismissed the petition on the basis that Appellant had repeated claims that were unsuccessfully presented in previous habeas petitions; (2) the repetition of Appellant's previous claims represented an abuse of the writ; and (3) the circuit court was not required to hold a hearing on the petition. View "Jackson v. Kelley" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis in his criminal case, holding that the State did not violate Brady v. Maryland, 373 U.S. 83 (1963), by withholding fingerprint evidence.Petitioner was convicted of second-degree unlawful discharge of a firearm from a vehicle and possession of firearms by certain persons and was sentences as a habitual offender to an aggregate term of 360 months' imprisonment. The court of appeals affirmed. In his coram nobis petition, Petitioner raised a Brady claim, asserting that the State withheld evidence that was both material and prejudicial. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate that the State withheld material evidence. View "Oliver v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not determining that Appellant failed to state grounds demonstrating probable cause that he was being illegally detained.In his petition, Appellant argued that the general principle in Miller v. Alabama, 567 U.S. 460 (2012) that mandatory life-without-parole sentences should not apply to juveniles under the age of eighteen should apply to him because he was still young and immature. The circuit court denied relief, finding that Miller has not be applied to extend relief to offenders over the age of eighteen. The Supreme Court affirmed, holding (1) the circuit court properly denied Appellant's petition for writ of habeas corpus; and (2) Appellant did not establish that he was entitled to a hearing. View "Benton v. Kelley" 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 and denied Appellant's petition for writ of certiorari, holding that the circuit court did not clearly err when it denied Appellant's habeas petition.In his habeas petition, Appellant alleged that the trial court in his criminal case did not conduct a plea hearing and therefore lacked the authority to enter a judgment of conviction. The circuit court concluded that Appellant failed to demonstrate probable cause that the writ should issue. The Supreme Court affirmed, holding (1) the circuit court did not clearly err when it denied Appellant's habeas petition; and (2) Appellant's petition for writ of certiorari is denied. View "Morgan v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court admitting, at Defendant's sentencing trial for the murder of his wife, a Defendant's letter requesting the proceeds of his wife's insurance policy, holding that the circuit court did not abuse its discretion in determining that the probative value outweighed the prejudicial impact.Defendant stabbed his wife to death outside their home and pleaded guilty to first-degree murder. Defendant reserved sentencing for a jury. At sentencing, the State introduced a letter to Defendant from the provider of Defendant's wife's life insurance policy informing him that he was a named beneficiary. Defendant wrote at the bottom of the letter that "I....would like to receive the payment payable to me from my wife [sic] policy." The Supreme Court affirmed the decision of the circuit court to admit the letter, holding that the letter was properly admitted to provide evidence of Defendant's motive for the murder and to display Defendant's conduct after the murder. View "Burnell v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of two specifications of cruelty and maltreatment and two specifications of failure to obey an order or regulation entered by the Arkansas Army National Guard in a court-martial proceeding, holding that there was no court-martial jurisdiction for those offenses under Ark. Code Ann. 12-64-801.On appeal, Defendant, a member of the Arkansas Guard, argued that because he was not in a "duty status" at the time of the incident that led to his court-martial, the court-martial lacked jurisdiction over him. The Supreme Court agreed, reversed the lower tribunal's determination on jurisdiction, and dismissed, holding that because the offenses occurred while Defendant was not in a duty status, there was no court-martial jurisdiction. View "Childers 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 stated no ground on which the writ could issue under Arkansas law.Appellant was found guilty of two counts of the rape of two children. Appellant was sentenced to thirty years' imprisonment on each of the two counts of rape. In his petition for writ of habeas corpus, Appellant alleged that the sentence imposed was excessive and based on "junk science"; (2) inadmissible testimony was allowed in the sentencing phase; and (3) he was denied the right to allocution before the sentence was imposed. The Supreme Court affirmed, holding that none of Appellant's claims stated a ground for the writ. View "Abernathy v. Kelley" on Justia Law

The Supreme Court dismissed Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, holding that this petition was an abuse of the writ.Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. In his pro se third petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis Petitioner alleged that the State violated Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court dismissed the petition, holding that Petitioner abused the writ in this instance because he alleged no fact sufficient to distinguish his claims from the claims in his first two petition. View "Barnett v. State" on Justia Law