Justia Criminal Law Opinion Summaries

The Supreme Court denied Defendant's petition for permission to file a writ of error coram nobis in the trial court, holding that the petition contained no allegations of trial error warranting coram nobis relief.Defendant was convicted of drug-related offenses and was sentenced as a habitual offender to an aggregate sentence of 2,200 months' imprisonment. The conviction was affirmed on appeal. Defendant sought permission to petition for writ of error coram nobis, asserting trial error in admitting evidence of his prior felony convictions and a violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petition, holding that Defendant's claims did not establish grounds for the writ. View "Von Holt 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 pursuant to Act 1780 of 2001, Ark. Code Ann. 16-112-201 to -208, holding that because Appellant had already raised the same issue in an earlier petition, the circuit court did not err when it declined to grant the writ.In 1992, Appellant was found guilty of rape and theft of a van and sentenced to forty years' imprisonment. In 2015, Appellant filed his first habeas petition seeking testing on vaginal swabs of the victim. The circuit court denied relief, and the Supreme Court affirmed. In 2018, Appellant filed a second petition for writ of habeas corpus again seeking DNA testing of a vaginal swab recovered from the victim. The circuit court denied relief. The Supreme Court affirmed, holding that where Appellant already raised his claim to the circuit court and it was rejected on appeal, he was not entitled to relief on the same allegation in the subsequent petition. View "Makkali 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 there was no error.Specifically, the Supreme Court held that the circuit court correctly denied Appellant's claim that he was being illegally detained because (1) by raising the same allegations that Appellant had already considered, Appellant abused the writ; (2) Appellant did not establish that there was error in the judgment of conviction that deprived the trial court of jurisdiction in the matter or rendered the judgment invalid; and (3) the fact that the circuit court permitted Appellant to proceed with his habeas petition without paying a filing fee was not tantamount to issuance of the writ. View "Anderson v. Kelley" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for writ of habeas corpus seeking scientific testing of evidence from his criminal case, holding that Appellant failed to establish the timeliness of the petition or its merit.Appellant was found guilty in 1994 of capital murder with the underlying offenses of kidnapping and rape and was sentenced to life imprisonment without parole. In 2019, Appellant filed the instant petition for scientific testing of evidence pursuant to Ark. Code Ann. 16-112-201 to -208. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant did not establish by clear and convincing evidence that no reasonable fact-finder would find him guilty of the murder of the victim based on any specific testing; (2) Appellant did not satisfy any of the factors that would establish that his petition was timely; and (3) the trial court was not obligated to hold a hearing on the petition. View "Mills v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from an order denying his pro se petition for permission to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that the circuit court had no jurisdiction to consider the petition.Appellant entered negotiated guilty pleas to rape and other offenses. Appellant later filed a petition for writ of error coram nobis in the Chicot County Circuit Court, the court where he was incarcerated, setting out two grounds for coram nobis relief. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that jurisdiction lay in the trial court where Appellant was convicted, which in this case was the Ashley County Circuit Court. Therefore, the Chicot County Circuit Court was without jurisdiction to address Appellant's coram nobis petition. View "Ray v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for declaratory judgment, holding that Appellant could not use a declaratory-judgment action to collaterally attack his criminal conviction.Appellant was convicted of first-degree murder and second-degree unlawful discharge of a firearm from a vehicle. The court of appeals affirmed. Years later, Appellant filed a petition for declaratory judgment alleging that he was denied due process in his criminal trial when the court admitted the prior testimony of an unavailable witness and that this admission violated the Confrontation Clause. The circuit court denied the petition. The Supreme Court affirmed, holding that a declaratory judgment action provided no relief on these grounds. View "Walker v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's "motion for credit for time spent in custody," holding that the circuit court's findings were not clearly erroneous.In his motion, Appellant alleged that he was entitled to 312 days of jail-time credit and that the circuit court should enter a new sentencing order nunc pro tunc that reflected the correct amount of jail-time credit. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court's denial of Appellant's motion was not clearly erroneous because Appellant failed to demonstrate a clerical error subject to correction. View "Barnett v. State" 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 stated no ground on which the writ could issue.Appellant was convicted of aggravated robbery, theft of property, and second-degree battery and sentenced as a habitual offender to an aggregate term of 660 months' imprisonment. The court of appeals affirmed. Appellant later petitioned for writ of habeas corpus, asserting that the trial court misapplied Arkansas's habitual-offender statutes. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the issues Appellant raised in his petition for the writ should have been raised at trial, on direct appeal, or in a petition for postconviction relief. View "Mason v. Kelley" on Justia Law

The Supreme Court affirmed Appellant's conviction of two counts of aggravated robbery, one count of theft of property, and one count of possession of a firearm by certain persons, holding that substantial evidence supported one of the aggravated robbery counts and that the circuit court did not err when it denied Appellant's motions to dismiss for speedy trial violations.On appeal, Appellant argued, among other things, that the circuit court erred when it denied his directed verdict motion with respect to one of the aggravated robbery counts. The Supreme Court affirmed, holding (1) substantial evidence supported the aggravated robbery conviction; and (2) Appellant's motions to dismiss for speedy trial violations were properly denied. View "McCray v. State" on Justia Law

The Supreme Court denied Petitioner's motion asking the Court to proceed with a belated appeal of a judgment reflecting his conviction on drug-related charges, holding that the trial court did not err in finding that Petitioner waived his right to appeal and that trial counsel had performed within an objectively reasonable standard.As grounds for the motion, Petitioner asserted that he asked counsel to appeal. The matter was remanded for a hearing. The trial court ultimately concluded that Petitioner waived his right to appeal and that counsel acted within an objective standard of reasonableness in not pursuing an appeal. The Supreme Court affirmed, holding that the trial court's conclusions were supported by the transcript and were not clearly erroneous. View "Smith v. State" on Justia Law