Justia Criminal Law Opinion Summaries

In this criminal case before the Supreme Court of Arkansas, the appellant, Fredrick Jones, was convicted by the Pulaski County Circuit Court of first-degree murder, first-degree battery, simultaneous possession of drugs and firearms, possession of cocaine with the purpose to deliver, possession of drug paraphernalia, fleeing, and being a felon in possession of a firearm. Jones was sentenced as a habitual offender to life in prison for the first-degree murder, sixty years in prison for first-degree battery, and an aggregate term of forty years on the remaining convictions, all to be served concurrently.The case resulted from an incident on April 25, 2020, where Jones shot a man and subsequently fled from the police the next day when the victim's daughter identified him. During the high-speed chase, Jones ran a red light, striking a van occupied by Jose and Virginia Hernandez. Jose Hernandez died from his injuries and Virginia Hernandez suffered serious physical injuries. The police discovered firearms and cocaine in Jones's vehicle after the crash.Jones appealed his convictions for first-degree murder and first-degree battery, arguing that the state had failed to prove that these crimes were committed "in furtherance of" his fleeing from police. He contended that while he drove his vehicle at a high speed and ran a red light to evade the police, the collision with the victims' vehicle and the resulting injuries did not promote his flight.The Supreme Court of Arkansas affirmed the lower court's convictions. The court held that there was substantial evidence proving that Jones, with the intent to evade the police (the underlying felony), caused the death of Jose Hernandez and seriously injured Virginia Hernandez in the process of fleeing. The court explained that for a conviction of felony murder, the defendant's primary goal must be the commission of the underlying felony, not the murder or battery itself. The court found that Jones's primary intent was to flee from the police, and in the course of and in furtherance of that flight, he caused the death and serious physical injuries. Therefore, the court ruled that the circuit court properly denied Jones's motions to dismiss. View "JONES v. STATE OF ARKANSAS" on Justia Law

In the case heard before the Supreme Court of Arkansas, the appellant William Tod Rickert was appealing his convictions from the Faulkner County Circuit Court for three counts of rape. Rickert was sentenced as a habitual offender to three life sentences, to be served concurrently. Rickert's main arguments for the appeal were that the circuit court erred by not directing verdicts on each of the three counts of rape; the circuit court abused its discretion in admitting evidence of prior bad acts under the pedophile exception; and the circuit court abused its discretion by admitting the certified copy of his prior Indiana convictions.The Supreme Court affirmed the lower court's decision. The court found that the victim’s uncorroborated testimony describing penetration may constitute substantial evidence to sustain a rape conviction, even when the victim is a child. The court also noted that scientific or medical evidence is not required. The court rejected Rickert's argument that the testimony of prior victims was inadmissible due to their gender difference and the time gap, citing previous cases where such testimonies were upheld. The court also found that the lower court did not err in admitting the certified copy of Rickert's Indiana convictions for the molestation and confinement of a previous victim.Thus, the court affirmed the circuit court's decision and Rickert's convictions. The court also conducted a Rule 4-3(a) review due to the life sentences and found no other prejudicial errors. View "RICKERT v. STATE OF ARKANSAS" on Justia Law

Rodney Dale Harmon was convicted of multiple drug-related felonies and sentenced to forty years in prison. During the execution of a search warrant at Harmon's residence, an HBO documentary film crew was present. The footage of the search, however, could not be obtained. Harmon, in his appeal, claimed that the presence of the film crew violated his Fourth Amendment rights. He filed a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37, which was denied by the circuit court.The Supreme Court of Arkansas affirmed the circuit court’s decision. The court stated that although Harmon argued that the presence of the HBO documentary film crew violated his Fourth Amendment rights, a constitutional violation alone does not trigger the application of Rule 37. The court also stated that issues related to the legality of evidence obtained are not of such a fundamental nature as to void the judgment. The court further noted that Harmon's trial counsel was not ineffective for failing to raise this argument as the remedy for such a violation in the context of a criminal trial is not established law. The court concluded that Harmon's petition conclusively showed that he was entitled to no relief and therefore, the circuit court did not err by dismissing the petition without a hearing. View "HARMON v. STATE OF ARKANSAS" on Justia Law

The Supreme Court of Arkansas heard an appeal from Michael Jenkins, who was challenging the denial of his pro se petition for a writ of "mandamus/prohibition" by the Jefferson County Circuit Court. Jenkins, who was convicted of first-degree sexual assault in 2018 and sentenced to 180 months' imprisonment, claimed that the Arkansas Department of Correction (ADC) and its record keeper had incorrectly deemed him ineligible for parole. He argued that the application of Arkansas Code Annotated section 16-93-609(b), which disqualifies for parole a sex offender previously convicted of a violent felony, was an ex post facto violation as it was based on his 1981 convictions for armed robbery and home invasion in Illinois - offenses that occurred before the enactment of the cited statute.The Supreme Court of Arkansas held that there was no ex post facto violation in the ADC’s application of the statute to Jenkins's parole eligibility. The court pointed out that the statute was enacted in 2001 and eliminates parole eligibility for persons who committed a felony sex offense after August 13, 2001, and had been previously convicted of a violent felony offense or any felony sex offense. Jenkins was convicted of a sexual assault committed in 2016, and his previous violent offenses committed in Illinois before the act's enactment were valid grounds for the application of section 16-93-609(b)(2). Consequently, the court affirmed the lower court's denial of Jenkins's petition for a writ and also denied his motion for the appointment of counsel. View "JENKINS v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

In the case before the Supreme Court of Arkansas, Rodney Dale Harmon, who was convicted of multiple drug-related felonies and sentenced to 40 years in prison, appealed the denial of his petition for postconviction relief under Arkansas Rule of Criminal Procedure 37. The appeal was mainly based on the presence of an HBO documentary film crew while a search warrant was executed at his home, and he argued that this violated his Fourth Amendment rights.The court ruled that claims related to the presence of the film crew during the search could not be used to void the judgment, as even constitutional violations are not in themselves enough to trigger application of Rule 37. The court further noted that issues of evidence, including those possibly obtained by illegal search or seizure, are not of such a fundamental nature as to void the judgment.Harmon also claimed that his trial counsel was ineffective for failing to raise the Fourth Amendment violation as an independent ground to suppress the evidence obtained in the search. The court disagreed, stating that even though the violation was established law, the remedy was not, and that counsel was not deficient for failing to raise a novel argument.Thus, the court affirmed the circuit court's denial of Harmon's petition for postconviction relief. View "HARMON v. STATE OF ARKANSAS" on Justia Law

In the Supreme Court of Arkansas case, Jeffery Allen Workman was convicted of first-degree murder, aggravated residential burglary, and second-degree battery, and sentenced to consecutive sentences of life in prison. The charges originated from an incident where Workman broke into a residence to retrieve a computer and in the process, shot and killed a man named David Basham. On appeal, Workman argued that the State failed to provide substantial evidence that he committed first-degree murder. However, the Supreme Court found that Workman failed to properly preserve this issue for appeal, as he did not renew his motion for a directed verdict at the close of all the evidence as required by the Arkansas Rules of Criminal Procedure. Therefore, the court affirmed his convictions. Additionally, the court conducted a Rule 4-3(a) review due to Workman's life imprisonment sentence and found no reversible error. View "WORKMAN, v. STATE OF ARKANSAS" on Justia Law

In this case, the Supreme Court of Arkansas was asked to consider an appeal by Maurice Trammel, who was challenging the denial of his petition to proceed in forma pauperis in seeking a declaratory judgment and a writ of mandamus. Trammel had been sentenced to 240 months' imprisonment for various crimes and was designated as a habitual offender. He sought to challenge his habitual offender status, arguing that there was no proof offered by the State that demonstrated he had committed the necessary number of felonies to be classified as such. He further argued that his sentence should be declared illegal, which would effectively reduce his period of parole eligibility.The Supreme Court of Arkansas held that Trammel did not state a colorable cause of action and that his petition was effectively a collateral attack on his sentence, which should have been raised in timely postconviction petitions. The court noted that Trammel was charged as a habitual offender and pleaded guilty to all the charges, including his habitual-offender status. His challenge to the sufficiency of the evidence supporting his habitual offender status was not a jurisdictional issue and was therefore waived by his guilty plea. Moreover, the court observed that the Department of Correction had no authority to modify a sentence imposed by a circuit court.Hence, the court affirmed the circuit court's denial of Trammel's in forma pauperis petition, finding no abuse of discretion in the circuit court's conclusion that Trammel had failed to state a justiciable controversy that would entitle him to declaratory relief. View "TRAMMEL v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

In the case before the Supreme Court of Arkansas, the appellant, Michael Driver, contested his convictions for rape and second-degree sexual assault. Driver argued that there was insufficient evidence to convict him, that his statements to the police should not have been admitted as evidence, and that the court abused its discretion by admitting evidence of non-charged conduct. The court affirmed Driver's convictions, determining that there was substantial evidence to support them.In November 2019, Driver was accused of raping a 12-year-old relative. The victim reported the incident, and the police found two used condoms with Driver's DNA at the location of the alleged rape. In the course of the investigation, another minor female relative also reported inappropriate sexual contact with Driver. Driver was interviewed by the police multiple times, during which he initially denied the allegations, but later confessed to the crimes. He was eventually arrested, tried, and found guilty.Driver's arguments on appeal were that there was not enough evidence to find him guilty, his statements to the police should not have been admitted because he had asked for legal counsel, and the court was wrong to admit evidence of non-charged conduct. However, the court found that there was sufficient evidence to support his convictions, his statements to the police were properly admitted as he had validly waived his rights to counsel, and the testimony of additional victims was not unfairly prejudicial. Therefore, the court affirmed his convictions. View "DRIVER v. STATE OF ARKANSAS" on Justia Law

In this case, the Supreme Court of Arkansas affirmed the denial of declaratory judgment and writ of mandamus petitions filed by Charles Sims, an inmate in the Arkansas Department of Correction (ADC). Sims had sought a declaration that he was eligible for parole, contrary to the determination made by ADC. The court affirmed the circuit court's finding that Sims was ineligible for parole according to the Arkansas Code.Sims had pleaded guilty to first-degree murder in 1995 and was paroled in 2007. In 2010, he pleaded guilty to first-degree battery and kidnapping, and was sentenced to concurrent terms of 180 months' imprisonment to run concurrently with his remaining sentence for first-degree murder. ADC records applied section 16-93-609 to Sims’s sentence for battery and kidnapping, determining him ineligible for parole.The court held that Sims had failed to establish a justiciable controversy or that he had a legal interest in the controversy, two prerequisites for declaratory relief. The court also noted that parole eligibility determinations fall within the purview of ADC, not the judiciary. The court further held that the absence of a reference to the parole-eligibility statute in the judgment did not constitute a requirement for parole eligibility.The court also dismissed Sims's argument that section 5-4-501(d)(2) was inapplicable to him, holding that the court has applied the relevant sections when the prior conviction consisted of only one offense. The court concluded that Sims had not established a right to parole eligibility, and therefore had no basis for the issuance of a writ of mandamus. The court affirmed the circuit court's decisions, ruling it did not clearly err or abuse its discretion when it denied and dismissed Sims's petitions for declaratory judgment and writ of mandamus. View "SIMS v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

In the case before the Supreme Court of Arkansas, the appellant, Cordale Stacy, was convicted of three counts of capital murder and sentenced to life imprisonment without parole on each count, along with a consecutive fifteen years’ imprisonment for a firearm enhancement. The appellant argued that the circuit court erred in denying his motions to dismiss the capital-murder charges due to an alleged overlap of capital, first-degree, and second-degree murder statutes.The case arose from a shooting incident in a Forrest City apartment where three individuals, an adult and two children, were found deceased. Witnesses identified Stacy fleeing the scene and further investigations led to his arrest. Stacy was charged with three counts of capital murder, possession of a firearm by certain persons, and a felony-with-a-firearm enhancement.Stacy filed two motions to quash the felony information, arguing that the capital murder statute overlapped with the first-degree murder statute for the adult victim, and overlapped with the first-degree and second-degree murder statutes for the minor victims. He contended that this overlap exposed him to an impermissible uncertainty in the offenses, which should have led to their dismissal. The circuit court denied both motions.On appeal, the Supreme Court of Arkansas held that there was no constitutional infirmity in the overlap of these statutes. The Court noted that each offense set forth different elements to be proved by the State, and thus, any alleged overlap presented no constitutional issues. Furthermore, the Court affirmed that the discretion of the prosecutor to choose between overlapping offenses did not violate the Equal Protection or Due Process Clauses. Therefore, the Court affirmed the circuit court's denial of Stacy's motions to quash the felony information and dismiss the charges. As a result, Stacy's conviction and sentence were upheld. View "STACY v. STATE OF ARKANSAS" on Justia Law