Justia Criminal Law Opinion Summaries

The Supreme Court dismissed this appeal from the circuit court's denial of Appellant's pro se petition for writ of habeas corpus, holding that Appellant's habeas petition was clearly without merit.Appellant filed a pro se petition for writ of habeas corpus in the circuit court, arguing, inter alia, that the trial court lacked jurisdiction to enter a judgment reflecting Appellant's conviction on a charge of second-degree murder as a habitual offender. The circuit court denied the dismissed the petition. Appellant appealed and filed pro se motions in which he sought a copy of documents from the record on appeal in order to prepare his brief and some accommodation for the delay in filing his brief. The Supreme Court dismissed the appeal, which rendered the motions moot, holding that Appellant's habeas petition was clearly without merit. View "Rainer v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for post conviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court correctly denied Appellant's Rule 37.1 petition.Specifically, the Court held that the circuit court (1) did not clearly err by finding that trial counsel's failure to obtain a forensic evaluation prior to Appellant's pleading guilty was not ineffective assistance; (2) did not err in finding that trial counsel was not ineffective by failing to file any pretrial motions to suppress or motions in limine before permitting Appellant to enter his plea; and (3) did not apply the wrong legal standard in ruling on Appellant's petition. View "Roos v. State" on Justia Law

The Supreme Court affirmed Appellant's two capital murder convictions, a firearm enhancement, and Appellant's sentence of death, holding that Appellant was not entitled to relief on his allegations of error.Specifically, the Court held that the circuit court (1) did not abuse its discretion in limiting Appellant's use of hypotheticals during voir dire; (2) did not abuse its discretion in concluding that a juror that Appellant argued should have been struck for cause could perform the duties of a juror; (3) did not abuse its discretion in denying Appellant's mistrial motion; (4) did not err in denying Appellant's request for an admonition; (5) did not abuse its discretion in allowing the State to play a tape recording of a 911 call; (5) did not err in admitting an aggravating circumstance to the jury; and (6) did not abuse its discretion in allowing the State's argument, during closing, that the jury should consider the victim-impact testimony as an aggravator. View "Reid v. State" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's motion for continuance to obtain an independent mental evaluation before convicting him of attempted capital murder, kidnapping, and theft of property, holding that Appellant failed to demonstrate any prejudicial from the denial of the continuance.Appellant sought a continuance to obtain an independent examination to support an affirmative defense of lack of criminal responsibility. The circuit court continued trial to accommodate the examination. After the examination returned unfavorable results, Appellant sought a continuance to obtain an independent evaluation. The circuit court denied the continuance. The Supreme Court affirmed, holding (1) the circuit court properly denied the request on the grounds that Appellant had not acted diligently; and (2) Appellant failed to demonstrate any resulting prejudice amounting to a denial of justice. View "Hendrix v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for writ of error coram nobis, rendering moot Appellant's request to file a belated reply brief, holding that Appellant did not demonstrate that the trial court abused its discretion in declining to issue the writ.In addition to his coram nobis petition Appellant filed a motion in which he sought to modify the record by removing portions that he alleged the trial court incorrectly considered and to seal the record. The Supreme Court denied Appellant's motion to modify and seal the record and denied Appellant's coram nobis petition, holding that Appellant's petition was clearly without merit. View "Gordon v. State" on Justia Law

The Supreme Court affirmed the circuit court's order denying Appellant's petition to proceed in the circuit court as a pauper with a petition for writ of habeas corpus, holding that none of Appellant's arguments on appeal demonstrated reversible error.In his habeas petition, Appellant challenged his convictions for four counts of computer exploitation of a child in the first degree and twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The circuit court found that Appellant presented sufficient evidence that he was indigent but that the allegations in the petition did not present a colorable cause of action. The Supreme Court affirmed, holding that Appellant's arguments made in the habeas petition were insufficient to present a colorable cause of action for habeas relief. View "Rea v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's motion for a new trial or other relief in which he sought a new sentencing hearing on his aggravated robbery conviction, holding that the circuit court did not err by denying the motion for new trial or other relief.On appeal, Appellant argued that his thirty-five-year sentence for aggravated robbery violated the protection afforded him by the federal Constitution because the jury was improperly instructed that it could consider and impose and sentence of life imprisonment, contrary to the holding in Graham v. Florida, 560 U.S. 48 (2010). The Supreme Court affirmed, holding that the circuit court was without jurisdiction to entertain Appellant's argument and thus did not err in denying Appellant's motion for new trial or other relief. View "Whiteside v. State" on Justia Law

The Supreme Court remanded this matter to the circuit court to settle the record, holding that this Court was unable to reach the merits of this appeal from the judgment of the circuit court finding Defendant guilty of first-degree murder, aggravated robbery, and theft of property.On appeal, Defendant argued that substantial evidence did not support his convictions, the circuit court abused its discretion on a juror misconduct allegation, and the record was inadequate on jury questions during deliberations. The Supreme Court remanded the case to the circuit court to settle the record, holding that the record was insufficient. View "Terry v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the writ.Appellant pleaded guilty to aggravated robbery and was sentenced to a term of imprisonment. In his petition for a writ of error coram nobis Appellant alleged that his counsel did not fully explain his parole eligibility or the effect of his prior convictions, and therefore, he was coerced into pleading guilty. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant's allegations did not rise to the level of coercion sufficient to meet his burden of establishing grounds for the writ. View "Brown v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a ground on which the writ could issue under Arkansas law.Appellant pleaded guilty to first-degree murder and was sentenced as a habitual offender to 600 months' imprisonment. In his habeas corpus petition, Appellant asserted several grounds for the writ. The circuit court concluded that the habeas petition was meritless. The Supreme Court affirmed, holding that where Appellant's petition consisted of blanket assertions that failed to show that there was a ground for the writ, the circuit court did not err in denying the petition. View "Loving v. Straughn" on Justia Law