Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to proceed in forma pauperis after seeking judicial review of Arkansas Department of Correction disciplinary proceedings under the Administrative Procedure Act, holding that Appellant failed to allege a basis for judicial review.Appellant, an inmate at the ADC, argued that he was prevented from presenting evidence and calling witnesses at his disciplinary hearing in violation of ADC policy and that his due process rights were violated thereby. The circuit court denied Appellant's petition to proceed as a pauper. The Supreme Court affirmed, holding that the circuit court properly denied Appellant's petition to proceed in forma pauperis because Appellant's underlying petition clearly failed to state a colorable cause of action. View "Perry v. State" on Justia Law

The Supreme Court affirmed the denial by the trial court of Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err by denying Appellant's numerous claims of ineffective assistance of counsel and that the trial court properly denied the petition without an evidentiary hearing.Appellant was convicted of capital murder, aggravated robbery, and kidnapping. The Supreme Court affirmed the convictions. Appellant later filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that the trial court did not err in denying postconviction relief and that Appellant was not entitled to an evidentiary hearing. View "Dennis v. State" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis and audita querela in his criminal case, holding that Petitioner's claims did not establish a ground for the writ.In his petition, Petitioner argued that the trial court erred in failing to apply the criminal code section that was in effect at the time was committed and that the prosecutor committed a Brady violation by withholding a medical report pertaining to an examination of the victim. The Supreme Court denied relief, holding that the existence of medical records that described the absence of corroborating physical evidence was known to defense counsel and that, even if the prosecutor had withheld this medical report, the outcome of the trial would not have changed as a result. View "Tolston v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1, in which he would challenge a judgment reflecting his sentence of life imprisonment without parole for capital murder, holding that Petitioner failed to set out a meritorious basis for relief under Rule 37.1.The judgment challenged by Petitioner was entered in 1978. In his petition, Petitioner alleged seven bases for grounds for Rule 37 relief, all framed as claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner failed to set forth meritorious grounds for postconviction relief under the Rule that may be included in the proposed petition. Therefore, the Court held, there was no need to reinvest jurisdiction in the trial court. View "Hallman v. State" on Justia Law

The Supreme Court affirmed the circuit court's dismissal of Plaintiff's complaint filed against Arkansas prison officials under the Arkansas Civil Rights Act and state tort law for allegedly depriving him of a nutritionally adequate diet safe for consumption but reversed the circuit court's imposition of a strike for the dismissal of the underlying action, holding that dismissal was warranted but the strike was not.In dismissing the complaint, the circuit court concluded that Plaintiff's claims were barred by sovereign and statutory immunity and failed to state facts upon which relief could be granted. The court also issued a strike under Ark. Code Ann. 16-68-607. The Supreme Court affirmed in part and reversed in part, holding (1) because Plaintiff's allegations failed to establish a constitutional violation Plaintiff failed to surmount sovereign and statutory immunity; and (2) the strike was unwarranted. View "Harmon v. Payne" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis, holding that Petitioner's claims were not cognizable in coram nobis proceedings.In his petition, Petitioner alleged that prejudicial testimony provided by the State's expert witness was admitted at trial without objection from counsel or an admonishment from the trial court and that the admission of this testimony deprived him of due process. The Supreme Court denied the petition, holding that there was no error in the admission of the allegedly prejudicial testimony, and therefore, Petitioner failed to allege a due process violation that would come within the purview of coram nobis relief. View "Henington v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of error coram nobis, holding that Appellant did not show an abuse of discretion in the denial of the writ.In 1979, Appellant was convicted of capital felony murder. After the Supreme Court gave Appellant leave to proceed with a coram nobis petition, Appellant filed his petition, alleging a violation of Brady v. Maryland, 373 U.S. 83 (1963). The trial court determined that no Brady violation had occurred and declined to issue the writ. On appeal, Appellant claimed that the trial court failed to conduct a proper analysis when it did not treat the admission of certain evidence as structural error and failed to apply the law of the case doctrine. The Supreme Court affirmed, holding that the error in this case was not structural and that the court was correct in its analysis. View "Pitts v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking permission to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1 in which Petitioner argued that he was entitled to collaterally attack his conviction and alternatively requesting that the Supreme Court recall the mandate for his two convictions, holding that Petitioner did not state a claim for relief.Petitioner argued that he was entitled to collaterally attack his conviction because the Arkansas statute under which his arrest warrants were issued was declared unconstitutional under Fairchild v. Lockhart, 675 F. Supp. 469 (1987). The Supreme Court held (1) Petitioner's reliance on Fairchild was unavailing, and even if Petitioner's arrest was illegal, it does not follow that his charges should be dismissed; and (2) Petitioner failed to establish any basis for the Supreme Court to recall its mandate. View "Logan v. State" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's petition seeking an extraordinary writ pursuant to the "all writ act" section 1651, holding that the circuit court did not clearly err when it denied Appellant's petition for an extraordinary writ.In his petition, Appellant, an inmate, sought to challenge the admissibility of evidence seized in an allegedly illegal search. The circuit court treated the petition as a petition for writ of habeas corpus and denied it. The Supreme Court affirmed, holding that, to the extent that Appellant sought a writ of habeas corpus, he did not state a cognizable claim. View "Douthitt v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of audita querela and for relief pursuant to Ark. R. Civ. P. 26(k), holding that the circuit court properly considered Appellant's petition as a coram nobis petition and that Appellant did not state a ground for a writ of error coram nobis.Appellant, an inmate, alleged in his petition for writ of audita querela that he was entitled to resentencing and that the judgment in his criminal case was invalid. The circuit court treated the petition as a petition for writ of error coram nobis and dismissed the petition. The Supreme Court affirmed, holding (1) it was not error for the circuit court to consider Appellant's petition as a coram nobis petition; and (2) the allegations that Appellant raised did not fit within the categories for claims that warrant issuance of a writ of error coram nobis. View "Jefferson v. State" on Justia Law