Justia Criminal Law Opinion Summaries

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow him to file a petition for writ of error coram nobis in his criminal case, holding that neither of Petitioner's claims established cause to permit Petitioner to proceed in the trial court with a coram nobis petition.Petitioner was found guilty of multiple drug-related offenses. As grounds for the writ, Petitioner alleged that (1) while his criminal case was on remand from the court of appeals, a third party confessed to him that he was the owner of drugs and scales seized in the search of Petitioner's house, and (2) neither Petitioner's trial attorney nor his appellate attorney afforded him effective assistance of counsel. The Supreme Court denied the writ, holding (1) Petitioner's petition with respect to the third-party confession was not timely filed; and (2) Petitioner's allegations of ineffective assistance of counsel were not cognizable in a coram nobis proceeding. View "McKinney v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for writ of error coram nobis, holding that reversal was not warranted because Appellant failed to establish a meritorious Brady claim.In 1994, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 2015, Appellant filed a petition to reinvest jurisdiction in the circuit court to consider his petition for error coram nobis on the ground that the State had suppressed exculpatory evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court ultimately denied the petition. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in denying Appellant's error coram nobis petition. View "Williams v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for a new trial based on postconviction DNA testing results, holding that the circuit court did not err in denying the motion and in not granting an evidentiary hearing before ruling on the motion.Defendant was convicted of rape, aggravated robbery, and burglary more than thirty years ago. In 2012, Defendant moved for postconviction DNA testing under Act 1780 of 2001 seeking to test for "touch DNA" on the knife found at the crime scene. The circuit court entered a stipulated order for postconviction DNA testing on the knife and several hairs and hair fragments. After testing was complete, Defendant moved for a new trial, relying on the DNA testing results. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion by denying Defendant's motion for new trial; and (2) did not abuse its discretion in finding that an evidentiary hearing was not required. View "Carter v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for various drug and drug-related offenses and sentencing him to an aggregate term of forty years' imprisonment, holding that the trial court did not abuse its discretion in admitting evidence of the presence of filmmakers at the search of Defendant's residence.When DEA officers and other law enforcement officers executed a warrant for the search of Defendant's home, they found drugs and drug paraphernalia. An HBO documentary film crew was present at the search under an agreement with law enforcement. The filmmakers did not participate in the search, nor did they include footage of the search in a documentary that later aired on HBO. On appeal from his convictions, Defendant argued, among other things, that the trial court abused its discretion by refusing to order the State to obtain the HBO video footage of the search of Defendant's home and to identify the filmmakers who were present. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in declining to order the State to obtain the video; (2) did not abuse its discretion in denying Defendant's request for a continuance; (3) did not abuse its discretion in granting the State's motion to exclude testimony about the film; and (4) erred in giving a nonmodel instruction, but the error was harmless. View "Harmon v. State" on Justia Law

The Supreme Court remanded this matter - which regarded Petitioner's pro se motions seeking to belatedly appeal his conviction, permission to proceed in forma paupers, and appointment of counsel - to the trial court for an evidentiary hearing, holding that the proper disposition of the matter required findings of fact.In his motion for belated appeal, Petitioner alleged that after he was convicted for aggravated assault on a family/household member he advised his retained attorney that he wished to appeal but that his attorney had failed to file a timely notice of appeal. The record did not contain an order relieving his attorney, so the question at issue was whether and when Petitioner communicated to his attorney that he wished to appeal and whether his attorney acted within an objective standard of reasonableness in not pursuing an appeal. The Supreme Court held that the proper disposition required findings of fact, and therefore, the matter must be remanded to the trial court for an evidentiary hearing. View "Marek 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, holding that Appellant did not state a ground in the petition on which the writ could issue.In 2011, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In his petition for writ of habeas corpus Appellant alleged that he was mentally incompetent both when the offense was committed and at the time of trial, that the evidence supporting his conviction was insufficient, and that, during the sentencing hearing, no mitigation evidence regarding his history of mental illness was submitted. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected the petition as not cognizable under long-standing interpretation of the Arkansas habeas statute. View "Leach 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 Appellant did not demonstrate clear error in the circuit court's dismissal of his petition.In 2008, Appellant was convicted for rape. In 2018, Appellant filed a habeas petition alleging that he had entered his plea in Desha County and that the court in that county lacked jurisdiction to conduct the plea hearing because the crime was committed in Chicot County and the judgement was entered there. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant's petition did not set out facts that would support a meritorious claim for relief. View "Williams v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions of first-degree murder, aggravated robbery, and theft of property, holding that the evidence was sufficient to support the convictions and that the circuit court did not abuse its discretion on a juror misconduct allegation.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion for directed verdict; (2) the circuit court did not abuse its discretion in not allowing Defendant to question a juror regarding her alleged head nod toward the victim's family after the jury had reached its verdicts in the guilt phase; and (3) the State rebutted the presumption of prejudice on the issue of whether the record was inadequate on jury questions during deliberations. View "Terry v. State" on Justia Law

The Supreme Court remanded this matter involving Defendant's motion for belated appeal, holding that the proper disposition of this case requires findings of fact, which must be made in the circuit court.Defendant was convicted of aggravated robbery and sentenced to 156 months' imprisonment. Defendant subsequently filed his motion requesting leave to proceed with a belated appeal of his conviction, arguing that he informed his retained trial counsel of his desire to appeal but that she did not file a notice of appeal. Defendant's lawyer disputed the account. The Supreme Court held that the proper disposition of the motion required findings of fact and therefore remanded the matter to the circuit court for an evidentiary hearing. View "Martin v. State" on Justia Law

The Supreme Court dismissed Defendant's appeal of the circuit court's dismissal of his petition to correct an illegal sentence, holding that the appeal must be dismissed because the petition was filed in the circuit court presiding over the county of Defendant's incarceration, rather than the court of conviction.Defendant was convicted by a Pulaski County jury of rape. Defendant was incarcerated at the Pine Bluff Unit of the Arkansas Department of Correction in Jefferson County when he filed a petition to correct an illegal sentence in the Jefferson County Circuit Court. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the Jefferson County Circuit Court lacked jurisdiction to consider the petition. View "Clark v. Kelley" on Justia Law