Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the circuit court denying Petitioner's petition for writ of habeas corpus, holding that Petitioner 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.Petitioner was convicted of second-degree murder and being a felon in possession of a firearm. The court of appeals affirmed. After Petitioner unsuccessfully sought postconviction relief he filed the petition for writ of habeas corpus in the county where he was incarcerated. Petitioner's ground for the writ was that, subsequent to his trial, the trial judge was accused of failing to abide by certain ethical and legal standards and was thus shown to be unqualified to preside as a judge. The trial court denied relief. The Supreme Court affirmed, holding that Petitioner did not state a ground upon which the writ could issue. View "Stalnaker v. Kelley" on Justia Law

The Supreme Court dismissed Appellant's appeal from the Jefferson County Circuit Court's denial of his pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101 to -123, holding that a writ of habeas corpus issued by the Jefferson County Circuit Court could not be returned because Appellant was no longer within its jurisdiction.Appellant, who was incarcerated in Jefferson County when he filed his petition, lodged an appeal from its denial and was later transferred to a prison facility in Lincoln County. The Supreme Court dismissed this appeal, holding that although Appellant was incarcerated in Jefferson County when he filed the habeas petition and proceeded with his appeal, the Jefferson County Circuit Court no longer had jurisdiction to hear the appeal. View "Reed v. Straughn" on Justia Law

The Supreme Court affirmed Defendant's conviction for rape, third-degree domestic battery, and other convictions, holding that the circuit court did not abuse its discretion in admitting certain testimony and that Defendant's remaining arguments were not preserved.On appeal, Defendant argued that the circuit court erred in allowing a witness to testify that she had also been raped by Defendant and that the trial court's exclusion of sexually explicit text messages and photographs of the witness, which were located on her phone, violated the Confrontation Clause. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in admitting the witness's testimony as independently relevant evidence proving Defendant's intent, motive, or plan was more probable than without the introduction of her testimony; and (2) Defendant's remaining arguments were not preserved. View "Fowlkes v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to recall the mandate to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's allegations failed to raise cognizable grounds for coram nobis relief or to recall the mandate.Petitioner was convicted of burglary, attempted burglary, and revocation of suspended sentences and subsequently convicted of rape, kidnapping, and residential burglary. Petitioner later filed his petition seeking coram nobis relief, alleging that both his trial and his direct appeal were defective. The Supreme Court denied the petition, holding that Petitioner's claims were not grounds for the writ. View "McCullough v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition and amended petition to correct an illegal sentence under Ark. Code Ann. 16-90-111, holding that Appellant did not establish that his sentence was illegal.Appellant plead guilty to capital murder, first-degree terroristic threatening, and second-degree battery. Appellant was sentenced to life imprisonment without the possibility of parole for the murder conviction. In this petition, Appellant argued that his sentence of life without parole was (1) illegal on its face because Ark. Code Ann. 16-89-108(b) provides that in cases in which the death penalty has been waived punishment could not be fixed at more than life imprisonment, and (2) was facially illegal because he signed the plea agreement before he entered his guilty plea but he did not initial each item on the agreement. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant's sentence was a legal sentence. View "Millsap v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, holding that there was no error in the circuit court's order denying Rule 37 relief.Defendant was convicted of capital murder and sentenced to death. Numerous proceedings followed. This appeal concerned Defendant's petition for postconviction relief. The circuit court entered an order denying Defendant relief on every claim. The Supreme Court affirmed, holding (1) there was no deficient performance by trial counsel under the Strickland standard; (2) the circuit court did not err in denying relief on the issue of Defendant's competency to stand trial; (3) Defendant's claim of juror misconduct was not cognizable in this postconviction proceeding; and (4) Defendant's remaining claims did not warrant reversal of his convictions. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court refusing to instruct the jury on two instructions proffered by Defendant at a resentencing hearing, holding that the circuit court did not err or abuse its discretion.Defendant, who was seventeen years old at the time of the offense, pled guilty to capital murder. After Miller v. Alabama, 567 U.S. 460 (2012), was decided, it was determined that Defendant should be resentenced by a jury. After a resentencing hearing, the jury imposed a sentence of life in prison. Defendant appealed, challenging the circuit court's rejection of two jury forms proffered by Defendant. The Supreme Court affirmed, holding that the circuit court did not err in denying the requested jury instructions. View "Grubbs v. State" on Justia Law

The Supreme Court affirmed the circuit court's order denying Defendant's petition for scientific testing of evidence, holding that the circuit court's decision denying the petition was not clearly erroneous.Defendant was convicted of rape, aggravated assault, and related convictions. Defendant later filed a petition under Ark. Code. Ann. 16-112-201 through 208 seeking further scientific testing of the vaginal swab collected from the victim. The trial court denied the petition. The Supreme Court affirmed, holding (1) where Ark. Code. Ann. 16-112-201 through 208 is the codification of Act 1780 of 2001 the circuit court did not err in applying Act 1780; (2) the circuit court did not err in denying Defendant's petition on the merits; and (3) the circuit court was not required to hold an evidentiary hearing on the petition. View "Rayfield 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 Ark. Code Ann. 16-112-101, holding that Appellant stated no basis for the writ.Appellant pleaded guilty to capital murder, attempted capital murder, and unlawful discharge of a firearm. Appellant later filed his petition for writ of habeas corpus, arguing that the State lacked jurisdiction to try him for the offenses because they were referred to as "international terrorism" committed by a "foreign terrorist organization" and that he was not afforded effective assistance of counsel. The Supreme Court affirmed, holding (1) the fact that Appellant's conduct could have been charged as a crime under a federal statute did not prohibit the State from trying him in state court; and (2) Appellant's claims of ineffective assistance of counsel were not cognizable as a ground for the writ. View "Muhammad v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's habeas corpus petition challenging a 1983 circuit court judgment reflecting Appellant's guilty plea to first-degree murder and the life sentence imposed, holding that Appellant did not demonstrate clear error by the circuit court.In his petition, Appellant alleged that he was actually innocent of the charge because he had been unaware when he entered his plea that he had a viable defense of justification and that trial counsel was ineffective for failing to investigate and develop a justification defense. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden of demonstrating a basis for the writ to issue. View "Crockett v. Kelley" on Justia Law