Justia Criminal Law Opinion Summaries

The Supreme Court remanded this case to the circuit court, holding that remand was required to accurately settle the record, specifically concerning Defendant's exhibit 1, a conventionally-filed physical disk that was submitted as part of the record but contained no files.Defendant was convicted of first-degree murder and sentenced to life imprisonment with a fifteen-year enhancement for firearm use. At issue on appeal was whether the circuit court erred in denying Defendant's motion for a mistrial during the guilt phase of trial. The Supreme Court remanded the case, holding that remand was required to rectify gaps in the record. View "Petty v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's two petitions for declaratory judgment and writ of mandamus wherein Appellant asked the circuit court to declare that he was entitled to parole and to direct his release on parole from the Arkansas Division of Correction (ADC), holding that there was no error.Appellant filed petitions for declaratory judgment and writ of mandamus asserting that the ADC violated Ark. Code Ann. 16-93-615(h), which was codified as section 16-93-1302(f) at the time Appellant committed the crime of rape, by denying him parole. The circuit court dismissed the petition, concluding that the issues raised therein was been addressed and resolved in Carroll v. Hobbs, 442 S.W.3d 834 (Ark. 2014). The Supreme Court affirmed, holding that the circuit court did not clearly err or abuse its discretion by denying and dismissing Appellant's petitions for declaratory and mandamus relief. View "Carroll v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err.In his section 16-90-111 petition, Petitioner alleged that consecutive sentences imposed upon revocation of suspended sentences in eight separate cases were illegal. Ark. R. Crim. Code 37.2(c) required Petitioner to file a Ark. R. Crim. Code 37.1 petition challenging the revocation of his suspended sentences within sixty days of the mandates issued by the court of appeals in May and July 2016. Petitioner, however, filed his petition to correct an illegal sentence almost four years later, in February 2020. The circuit court denied and dismissed the petition because Rule 37.1 had superseded it, and Petitioner's petition was untimely. The Supreme Court affirmed, holding that Petitioner was not entitled to relief. View "Todd v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition to correct an illegal sentence, holding that Petitioner failed to establish either that his sentence was illegal on its face or, at the time of sentence, that the sentencing court lacked subject-matter jurisdiction.Petitioner pleaded guilty to manslaughter and robbery and stipulated that he was a habitual offender. Petitioner was sentenced to sixty months in prison for manslaughter and 480 months for robbery, with his sentences to run consecutively. Petitioner later filed a petition for relief from an illegal sentence, which the circuit court denied. The Supreme Court affirmed, holding that Defendant's sentence fell within the maximum prescribed sentence and was legal on its face and that the circuit court did not clearly err in denying Petitioner's petition on all grounds. View "Harmon v. State" on Justia Law

The Supreme Court granted Petitioner's pro se petition for a writ of mandamus directing Honorable Quincy Ross, circuit judge, to issue an order acting on Petitioner's habeas petition within thirty days of the date of this opinion, holding that Petitioner was entitled to the writ.Petitioner pleaded guilty to theft of property and was sentenced to sixty months' imprisonment as a habitual offender. In his mandamus petition, Petitioner asserted that Judge Ross had failed timely to act on his petition for writ of habeas corpus. The Supreme Court granted the writ because Petitioner's habeas petition had been pending since 2021, no action had been taken, and the State's response offered no explanation for the extended delay. View "Davis v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to vacate and dismiss judgment and commitment order due to lack of jurisdiction filed under Ark. Code Ann. 16-90-111, holding that there was no error.In his motion, Appellant argued that the trial court lacked jurisdiction to convict him because he did not engage in the criminal conduct contemplated by Ark. Code Ann. 5-54-119 and because the elements of section 5-54-119 were not established. The Supreme Court affirmed the trial court's denial of the motion, holding that the trial court did not clearly err when it found that Appellant did not state a cause of action under section 16-90-111(a). View "Gonder v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting and sentencing Defendant for first-degree battery and failure to appear on a felony, holding that the circuit court did not abuse its discretion by denying Defendant's motion to substitute counsel and that there was substantial evidence to support Defendant's conviction for first-degree battery.After a three-day trial, the jury convicted Defendant of first-degree battery and failure to appear but acquitted him of second-degree battery. The Supreme Court affirmed, holding (1) because Defendant was indigent he was not entitled to the counsel of his choice, and therefore, the circuit court did not abuse its discretion in denying Defendant's motion to substitute counsel; and (2) the State introduced substantial evidence sufficient to support Defendant's conviction for first-degree battery. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the denial of Appellant's petition for writ of habeas corpus arguing that his sentence was illegal and that an amendment to the information was to vague to suffice as an amendment, holding that Appellant was not entitled to relief.After a jury trial, Appellant was convicted of possession of cocaine with intent to deliver. The jury sentenced Appellant as a habitual offender to a total of 125 years' imprisonment, and the court of appeals affirmed. Appellant later filed this petition for a writ of habeas corpus arguing that the State's oral amendment to the information was deficient. The circuit court denied the petition. The Supreme Court affirmed, holding that the trial court had authority to sentence Appellant as a habitual offender, and his sentence was within the range authorized under Ark. Code Ann. 5-4-501(b). View "Hogan v. Payne" on Justia Law

The Supreme Court affirmed Defendant's conviction of five counts of rape and his sentence to five concurrent terms of life imprisonment, holding that the circuit court did not abuse its discretion by denying Defendant's motion for a continuance.After a trial, Defendant was convicted of raping his minor stepson and sentenced to life imprisonment. On appeal, Defendant argued that the circuit court abused its discretion by denying a continuance to investigate a supplemental DNA report allegedly provided to the defense the Friday before trial. The Supreme Court rejected the argument and affirmed, holding that Defendant never requested a continuance to obtain an expert to perform DNA testing and that Defendant's argument was not preserved for appellate review. View "Grady v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder and his sentence of life imprisonment, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) as to four of Defendant's allegations of error on appeal, five of them were not preserved; (2) the trial court did not abuse its discretion by rejecting Defendant's proffered justification instructions; (3) the trial court did not prevent Defendant from testifying about the victim's past violent acts; (4) Defendant was not entitled to resentencing based on the standard sentencing range for a Class Y felony; and (5) the trial court did not abuse its discretion by admitting two challenged photographs. View "White v. State" on Justia Law