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 Petitioner did not meet his burden of establishing that he was entitled to coram nobis relief.In his petition, Petitioner asserted that the State withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963), by not turning over exculpatory evidence concerning DNA testing and a firearm that was not adequately tested by the State for fingerprints. The Supreme Court denied the petition, holding (1) the fact that certain scientific testing was not performed on an item in evidence did not constitute a showing that the testing was hidden by the State; and (2) Petitioner's remaining allegation was not within the purview of the writ. View "McKinney v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had the capacity to knowingly and intelligently waive his postconviction remedies, including his Ark. R. Crim. P. 37.5 petition, was not clearly erroneous and affirmed the circuit court's dismissal of Defendant's Rule 37.5 petition, holding that the court did not err.Defendant was convicted was capital murder and other crimes. Defendant later filed for postconviction relief pursuant to Ark. R. Crim. P. 37.5, arguing that counsel was constitutionally ineffective for failing to investigate sufficiently whether he was intellectually disabled. Counsel subsequently advised the circuit court that Defendant desired to waive his postconviction remedies, including his Rule 37.5 petition, which counsel asked the court to dismiss. After a hearing to determine whether Defendant had the capacity to waive his postconviction remedies, the circuit court concluded that Defendant's waiver was made knowingly and intelligently. The Supreme Court affirmed, holding that the circuit court did not err in dismissing Defendant's Rule 37.5 petition. View "Lard v. State" on Justia Law

The Supreme Court denied Petitioner's fourth pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate a fundamental error of fact that was extrinsic to the record that would warrant issuance of the writ.In his fourth coram nobis petition, Petitioner asserted his innocence and alleged that his trial was defective due to fraudulent testimony against him. Petitioner also challenged the sufficiency of the evidence and other asserted errors. The Supreme Court denied relief, holding that Petitioner was not entitled to coram nobis relief. View "Burks v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentence and granted Defendant's counsel's motion to withdraw, holding that no error occurred in the proceedings and that there were no nonfrivolous issues that supported an appeal in this case.Defendant was convicted of first-degree murder with a firearm and sentenced to life imprisonment. Defendant's counsel filed a motion to withdraw as counsel and a no-merit brief stating that there were no meritorious grounds to support an appeal. The Supreme Court affirmed Defendant's convictions and granted counsel's motion to withdraw, holding (1) Defendant's appellate counsel demonstrated that any appeal would be frivolous and that this appeal had no merit; and (2) no prejudicial error occurred in the proceedings below. View "Riley v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court resentencing Defendant to life imprisonment after his original life-without-parole sentence was vacated due to Miller v. Alabama, 567 U.S. 460 (2012), holding that the circuit court erred by allowing the jury to be informed of Defendant's prior sentence.Defendant pleaded guilty to capital murder and attempted capital murder and was sentenced to life without the possibility of parole. After Miller was decided, the Supreme Court granted habeas relief and remanded to the circuit court for a sentencing hearing where Defendant could present Miller evidence for consideration. The circuit court held a resentencing trial, and the jury sentenced Defendant to life. On appeal, Defendant argued that the circuit court erred by permitting the jury to be informed that Defendant was previously sentenced to life imprisonment without parole. The Supreme Court reversed and remanded the case for a new sentencing trial, holding that the circuit court abused its discretion in not excluding this evidence pursuant to Ark. R. Crim. P. 403 and that the error was not harmless. View "Kitchell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment, holding that the circuit court did not err in the proceedings below.Specifically, the Court held that the circuit court (1) did not err in denying Defendant's motions for directed verdict; (2) did not err in denying Defendant's motion to suppress his custodial statement; (3) did not err in denying Defendant's motion for mistrial based on a prejudicial outburst from the witness stand; and (4) did not err in excluding the testimony of a witness that Defendant alleged would have pointed to someone else as the killer. View "Halliburton v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court rejecting Appellant's proffered jury instructions at his resentencing hearing, holding that the circuit court did not abuse its discretion.At age seventeen, Appellant committed capital murder and rape. Appellant received a mandatory sentence of life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant's life sentence for capital murder was vacated. After a resentencing hearing a jury sentenced Appellant to life imprisonment. On appeal, Appellant argued that the circuit court erred in rejecting his proffered jury instructions on capital murder. The Supreme Court affirmed, holding that because Appellant's proffered instructions would ask the jury to make findings required only in death cases the circuit court properly refused to give those instructions. View "Hundley v. State" on Justia Law

The Supreme Court affirmed the circuit court's order denying Appellant's petition for a writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant did not state a ground for the writ.Appellant pled guilty to four counts of first-degree sexual assault. At the time of the trial court proceedings, Appellant requested a mental evaluation. After the circuit court granted the request Appellant withdrew the request and pled guilty. Thereafter, the forensic evaluation was submitted to the court with a finding that Appellant was competent and fit to proceed. In his habeas corpus petition, Appellant argued that the circuit court lacked subject matter jurisdiction to accept his guilty plea before the mental evaluation was filed. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was one that fell within the scope of habeas, but Appellant's claim that the circuit court was divested of jurisdiction due to the lack of a forensic report at that time of the proceeding failed. View "Hayes v. Kelley" on Justia Law

The Supreme Court denied Appellant's petition for rehearing of the Court's decision affirming the circuit court's denial of Appellant's petition for postconviction DNA testing under Act 1780, holding that Appellant's petition for rehearing failed to comport with the requirements set forth in Arkansas Supreme Court Rule 2-3(g).On appeal from the denial of his postconviction motion, the Supreme Court affirmed the conclusion of the circuit court that the proposed scientific testing under Act 1780 could not raise a reasonable probability that Defendant did not commit the murder for which he was convicted and that the admissibility of proffered eyewitness identification testimony was procedurally barred from consideration. In his petition for rehearing, Appellant reiterated the same arguments that were considered and rejected on appeal and, for the first time, asserted a constitutional claim. The Supreme Court denied the petition for rehearing, holding that the entirety of the petition fell outside the scope of rehearing under Rule 2-3(g). View "Johnson v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Appellant's two pro se petitions challenging his 1993 conviction for first-degree murder and sentence of life imprisonment, holding that the circuit court properly denied relief.The first petition Appellant filed sought scientific testing for habeas relief under Act 1780 of 2001 Acts of Arkansas, codified at Ark. Code Ann. 16-112-201 to -208. The second petition sought relief from an illegal sentence. The circuit court denied both petitions. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief under Act 1780; and (2) Appellant failed to allege facts that would support his claim of an illegal sentence. View "Mcarty v. State" on Justia Law