Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of first-degree murder and sentenced as a habitual offender to life imprisonment. More than thirty years later, Appellant filed his petition for writ of habeas corpus alleging that the judgment was void and the circuit court was without jurisdiction because the felony information charging him with the offense was not signed by the prosecuting attorney but, rather, was signed by a deputy prosecuting attorney on behalf of the prosecutor. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant did not state a basis for the writ. View "Davis v. Straughn" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the performance of Appellant's trial counsel was not deficient.Appellant was convicted of capital murder and sentenced to death. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5 alleging, among other claims, that trial counsel was ineffective concerning the mitigating circumstances presented to the jury and the failure to call any witnesses but his sister at the sentencing phase. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant's claim that he received ineffective assistance of counsel during the sentencing phase. View "Johnson v. State" on Justia Law

The Supreme Court denied Petitioner's second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and second petition for writ of certiorari, holding that Petitioner was not entitled to either coram nobis relief or issuance of a writ of certiorari.In two separate trials, Petitioner was convicted of the rapes of two girls and the rape of a five-year-old child and burglary. Petitioner subsequently filed multiple petitions for psostconviction relief, including the instant petitions for coram nobis relief and seeking issuance of a writ of certiorari. The Supreme Court denied coram nobis relief, holding (1) the claims raised in Petitioner's second coram nobis petition that reasserted claims raised in Petitioner's first coram nobis petition were an abuse of the writ; and (2) the remaining claims were either outside the scope on which the writ may issue or did not establish that Petitioner was entitled to coram nobis relief. The Court also denied Petitioner's petition for writ of certiorari, holding that the arguments in the petition could have been raised at trial or on direct appeal. The Court further denied Petitioner's motion for appointment of counsel as unwarranted and motion to withdraw as moot. View "Lukach v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's claims for postconviction relief raised under Ark. R. Crim. P. 37.1, holding that none of counsel's alleged errors created a reasonable probability of a different outcome had they not occurred.In denying postconviction relief, the trial court held that the alleged deficient actions of trial counsel were based on reasonable strategic and legal grounds and that counsel's alleged errors would not have changed the outcome of the trial. The Supreme Court affirmed, holding that to the extent trial counsel's performance arguably satisfied the first prong of Strickland, the failure did not satisfy the second prong - that Appellant's counsel's error was sufficiently prejudicial as to show a reasonable probability of a different outcome. View "Reynolds v. State" on Justia Law

The Supreme Court affirmed Appellant's conviction of capital murder, holding that the evidence was sufficient to sustain the conviction and that the circuit court did not err in denying Appellant's motion to suppress tracking data generated by his cellphone.On appeal, Appellant argued that the trial court erred by denying his directed-verdict motion because the evidence supported the defense's theory of the case that he did not intend to shoot the victim. Further, Appellant argued that the court abused its discretion in denying his motion to suppress evidence obtained from the seizure of AT&T phone records. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the capital murder conviction; and (2) the circuit court correctly denied the motion to suppress. View "Thomas v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to proceed in forma pauperis on a petition for writ of mandamus and a motion for declaratory judgment, holding that Appellant failed to state a colorable cause of action.In 1998, Appellant was convicted of rape. In his petition for a writ of mandamus, Appellant asserted that he sought information pursuant to the Arkansas Freedom of Information Act regarding his rape conviction but received no response. The circuit court denied the petition. The Supreme Court affirmed, holding (1) even if Appellant had requested disclosable information, he would not be entitled to inspect it as an incarcerated person; and (2) Appellant did not demonstrate a legitimate claim given the facts presented and therefore failed to establish a colorable cause of action to support his request to proceed in forma pauperis. View "Berger v. Bryant" on Justia Law

The Supreme Court denied Appellant's appeal from the order of the circuit court denying his petition to proceed in forma pauperis on the grounds that Appellant failed to state a colorable cause of action in a petition for writ of habeas corpus, holding that the circuit court did not abuse its discretion by denying Appellant's in forma pauperis petition.In his habeas petition, Appellant alleged that the trial court lacked jurisdiction in his criminal case. Before this case was submitted to the Supreme Court, Appellant filed two motions, including a "Judicial Notice of a Void Judgment" and a "Notice to the Court." The Supreme Court denied the motions, holding that neither motion was cognizable under the Court's rules. The Court then affirmed the Supreme Court's denial of Appellant's in forma pauperis petition, holding that the circuit court correctly found that Appellant did not assert a colorable cause of action. View "Chatmon v. Kelley" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's orders denying her motions to declare Ark. Code Ann. 5-62-106 (disposition of animal) and Ark. Code Ann. 5-62-111 (prevention of cruelty) unconstitutional and conditionally granting her motion for return of seized property, holding that there was no final, appealable order in this case.Appellant was convicted of thirty-one misdemeanor counts of cruelty to animals. The circuit court subsequently dismissed the charges on speedy-trial grounds. The State appealed, and the Supreme Court dismissed the appeal on the grounds that it was not authorized. Appellant had filed motions seeking a declaration that sections 5-62-106 and -111 are unconstitutional and seeking the return of her seized property. The circuit court denied the constitutional claims and entered a conditional order granting Appellant's motion for return of seized property. Appellant appealed. The Supreme Court dismissed the appeal, holding that because the conditional order did not make specific findings as to the return of the property or as to damages and because it expressly left open the possibility of further proceedings, there was no final, appealable order in this case. View "Siegel 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 the circuit court did not err in denying the petition.Appellant was found guilty of two counts of delivery of a controlled substance and one count of maintaining a drug premises. In his habeas petition, Appellant argued that he was actually innocent because his arrest and conviction was based on the false testimony of a witness who had a lengthy criminal history. Appellant further argued that the writ should issue because he was not afforded effective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims regarding the witness's credibility do not constitute a valid assertion that he was being unlawfully detained; and (2) Appellant did not actually connect an allegation of ineffective assistance of counsel to his allegation that he was unlawfully detained. View "Cave v. State" on Justia Law

The Supreme Court denied Petitioner's second petition requesting permission to proceed in the trial court with a petition for writ of error coram nobis, holding that Petitioner's proposed attack on the judgment had no merit.Petitioner was convicted of raping a mentally handicapped sixteen-year-old girl and was sentenced to life imprisonment. In his first petition for writ of error coram nobis Petitioner alleged a number of errors in the trial procedure. The first petition was denied. In his second coram nobis petition, Petitioner alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the writ, holding that Petitioner failed to meet his burden of demonstrating a fundamental error of fact extrinsic to the record. View "McClinton v. State" on Justia Law