Justia Criminal Law Opinion Summaries
Articles Posted in Arkansas Supreme Court
Mcarty v. State
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
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Arkansas Supreme Court, Criminal Law
Young v. Kelley
The Supreme Court affirmed the order of the circuit court denying and dismissing 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 under Arkansas law.Appellant pled nolo contendere to two counts of second-degree sexual assault. Appellant later filed the petition for writ of habeas corpus alleging claims of actual innocence and insufficient evidence. The circuit court denied the dismissed the petition. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of demonstrating that he was being illegally detained and entitled to issuance of a writ of habeas corpus to effect his release from custody; and (2) Appellant offered no well-founded argument for the Court to expand the writ. View "Young v. Kelley" on Justia Law
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Arkansas Supreme Court, Criminal Law
Marshall v. State
The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not clearly err when it denied relief.Appellant was convicted of aggravated residential burglary and sentenced to a term of life imprisonment. In his postconviction relief petition, Appellant alleged that counsel ineffectively requested trial continuances without legal bases or good cause, thus depriving him of his speedy trial rights. The trial court denied the petition. The Supreme Court affirmed, holding that, even assuming that counsel's requests delayed Appellant's trial without a legal basis, Appellant failed to demonstrate that he was prejudiced as a result of those alleged errors. View "Marshall v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Collier v. Kelley
The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.Appellant pleaded guilty to first-degree murder and other crimes. In his habeas petition, Appellant argued that the judgments in three counties reflected the incorrect legal name, making the convictions facially invalid. The circuit court declined to issue the writ. The Supreme Court affirmed, holding that Appellant's challenge to the misnomer on the judgment and commitment orders was a mere allegation of trial error and not the type of defect that implicates the facial validity of a trial court's judgment or jurisdiction. View "Collier v. Kelley" on Justia Law
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Arkansas Supreme Court, Criminal Law
Mabry v. State
The Supreme Court affirmed Defendant's conviction of six counts of rape, holding that no reversible error occurred in the proceedings below.Defendant was sentenced for life imprisonment for each count of rape, with the sentences to be served consecutively. Because Defendant received a sentence of life imprisonment, the Supreme Court reviewed the record for all errors prejudicial to Defendant. The Supreme Court affirmed, holding that the circuit court did not commit prejudicial error (1) in denying Defendant's motion for a directed verdict because substantial evidence supported the conviction; (2) in making three evidentiary rulings; and (3) in denying Defendant's motion for a mistrial. View "Mabry v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Lovelace v. Kelley
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's duplicate petitions for writ of habeas corpus, holding that the petitions failed to allege a basis for the writ.Approximately forty years ago, Appellant was convicted of aggravated robbery and sentenced to life imprisonment. This appeal concerned the circuit court's denial and dismissal of his duplicate pro se petitions for writ of habeas corpus. In his petitions, Appellant asserted that his conviction was void because the criminal information was signed by the deputy prosecuting attorney instead of the elected prosecuting attorney. The circuit court denied and dismissed the petitions. The Supreme Court affirmed, holding that the circuit court did not clearly err. View "Lovelace v. Kelley" on Justia Law
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Arkansas Supreme Court, Criminal Law
Halfacre v. Kelley
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in rejecting Appellant's petition.Appellant was convicted of two counts of aggravated robbery. In his habeas petition, Appellant argued that his aggravated robbery convictions were invalid because the criminal statutes under which he was convicted were unconstitutional. The circuit court rejected Appellant's argument. On appeal, Appellant further argued that the state habeas corpus statute is unconstitutional. The Supreme Court affirmed, holding (1) the aggravated robbery statute does not violate the Arkansas Constitution; and (2) Appellant's challenge to the constitutionality of the habeas corpus statute is waived because it was not raised or ruled on below. View "Halfacre v. Kelley" on Justia Law
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Arkansas Supreme Court, Criminal Law
Beard v. State
The Supreme Court reversed Defendant's conviction of one count of rape and two counts of second-degree sexual assault and sentence of life imprisonment plus forty years, holding that the circuit court erred in overruling Defendant's objection when an investigator testified that she found the allegations of sexual abuse were true and that the victims were "very credible."On appeal, the State conceded that the circuit court erred in admitting the investigator's testimony about the victims' credibility. At issue before the Supreme Court was whether the error was harmless. The Supreme Court held that where the victims' testimony was the only evidence supporting conviction it cannot be said that the circuit court's error in admitting the testimony was slight. Accordingly, the Supreme Court reversed Defendant's convictions and remanded for a new trial. View "Beard v. State" on Justia Law
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Arkansas Supreme Court, Criminal Law
Weeks v. Thurston
The Supreme Court reversed the order of the circuit court disqualifying district judge Adam Weeks from the ballot for the judicial office of the Third Judicial District, Division Three, Circuit Judge in the March 3, 2020 election, holding that a conviction under Ark. Code Ann. 27-14-306 does not require the finder of fact to find, or the defendant to admit, an act of deceit, fraud, or false statement.The circuit court removed Weeks' name from the ballot because he was previously convicted for violating the "fictitious tags" statute, section 27-14-306. At issue was whether the statute constitutes a misdemeanor offense in which the finder of fact was required to find an act of deceit, fraud, or false statement. The Supreme Court reversed, holding that a violation of section 27-14-306 did not require a finding of admission of deceit, fraud, or false statement, and therefore, Weeks was eligible to run for public office. View "Weeks v. Thurston" on Justia Law
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Arkansas Supreme Court, Criminal Law
Muhammad v. Kelley
The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in dismissing Appellant's petition.In dismissing Appellant's petition the circuit court found that the petition was defective because Appellant had failed to attach a copy of his judgment and commitment order or provide a legal excuse for the omission and, further, that Petitioner's claim was without merit. The Supreme Court affirmed the dismissal, holding that because Appellant's habeas petition failed to comply with the requirements of Ark. Code Ann. 16-112-103(b) the circuit court properly dismissed the petition. View "Muhammad v. Kelley" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law