Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to demonstrate probable cause for issuance of the writ.Appellant was found guilty of three counts of aggravated robbery and one count of theft of property and sentenced to three life sentences. Appellant later filed a petition for writ of habeas corpus alleging that his convictions were invalid because the circuit judge who presided over his trial did not legally hold the position. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ. View "Chatmon v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's petition for a writ of habeas corpus and denied his motion to amend his reply brief, holding that there was no error.Appellant filed a petition for a writ of habeas corpus alleging that his sentence exceeded the maximum authorized by Ark. Code Ann. 5-64-422 and that the statute of limitations had expired on the primary offense underlying his engaging in a continuing criminal enterprise conviction. The Supreme Court affirmed, holding (1) Appellant's sentence was well within the statutory limits and was not illegal; and (2) the criminal information was timely filed for statute of limitations purposes. View "Hunter v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for a writ of habeas corpus filed in the county of his incarceration, holding that there were no grounds, stated in either the petition filed in the circuit court or in Appellant's arguments, on which a writ of habeas corpus could issue.On appeal, as he did below, Appellant argued that the trial court lacked jurisdiction to try and convict him by failing to adhere to Arkansas Supreme Court Administrative Order No. 5 and because he was not allowed to present certain evidence that would have exonerated him. The Supreme Court affirmed, holding there was no basis for finding that a writ of habeas corpus should issue. View "Lowery v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's motion to withdraw his guilty, his petition to correct an illegal sentence imposed in an illegal manner, his petition to vacate and set aside or correct his sentence, and his motion for a new trial, holding that there was no clear error.In denying postconviction relief, the circuit court found that Appellant's multiple requests failed to meet the verification requirement of Ark. R. Crim. P. 37.1 and were otherwise untimely under Rule 37.2(c). The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied and dismissed Appellant's motions and petitions to withdraw his plea as unverified and to set aside his sentences as untimely. View "Dillon v. State" on Justia Law

In this interlocutory appeal, the Supreme Court reversed the order of the circuit court disqualifying defense attorney Patrick Benca as Defendant's counsel in this criminal action, holding that the circuit court abused its discretion by disqualifying Benca from representing Defendant.Defendant was convicted of first-degree murder, but the convictions were reversed due to evidentiary error. Benca represented Defendant at his second trial. After a mistrial was declared due to Benca's becoming a witness during the second trial, the circuit court made clear that Benca was disqualified from participating as counsel for Defendant. Defendant was convicted after a third trial, at which he was represented by different attorneys. The conviction was reversed due to prosecutorial misconduct. Defendant retained Benca to represented him at his fourth trial, but the circuit court refused to recognize Benca as attorney of record based on the earlier order finding that Benca was disqualified. The Supreme Court reversed the order, holding that the circuit court abused its discretion by disqualifying Benca from representing Defendant. View "Stanton v. State" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that the circuit court did not err in denying and dismissing the petition.In his petition, Appellant alleged that the original sentencing order was illegal because he had been charged as a habitual offender and was not entitled to probation and, therefore, the order revoking his probation and increasing his sentence was illegal. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied and dismissed Appellant's petition for the writ. View "Livingston v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that Appellant, an inmate, had failed to state a ground for a writ of habeas corpus, holding that there was no error.Appellant brought a petition for writ of habeas corpus asserting that, in two separate cases involving multiple crimes, there was error in the charging and trial court process. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant's claims that he was never properly arraigned, appointed counsel, or served with an arrest warrant for the rape and kidnapping charges did not implicate the facility validity of the judgment or the trial court's jurisdiction, and therefore, the writ of habeas corpus should not be issued. View "Crawford v. Payne" on Justia Law

The Supreme Court affirmed Defendant's convictions for three counts of first-degree murder and other crimes and his sentence of three consecutive life sentences plus sixty-five years' imprisonment, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) Defendant failed to preserve for appeal his argument that the circuit court erred in denying his motion for directed verdict on count six because the State failed to name the victim of that offense in the criminal information; (2) the circuit court did not impermissibly stack enhancements in sentencing Defendant; (3) the circuit court did not commit reversible error in excluding certain testimony as hearsay; (4) the circuit court did not abuse its discretion in denying Defendant's proffered manslaughter jury instruction. View "Tucker v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of the rape of a minor child and sentencing him as a habitual offender to life imprisonment, holding that Appellant was not entitled to relief on his claims of error.On appeal, Appellant argued that substantial evidence did not support his conviction and that the circuit court abused its discretion in denying his motion for a continuance. The Supreme Court affirmed, holding (1) Appellant's rape conviction was supported by substantial evidence; (2) the circuit court did not abuse its discretion in denying Appellant's continuance motion; and (3) under Ark. Sup. Ct. R. 4-3(a), no prejudicial error was found. View "McCauley v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction and the denial of his petition for a writ of error coram nobis, holding that there was no error.After Defendant was convicted he filed a motion to stay briefing and reinvest jurisdiction with the circuit court to consider a petition for writ of error coram nobis. The Supreme Court granted the motion. An amended sentencing order was subsequently filed reducing Defendant's conviction to murder in the second degree and his sentence to twenty years. After a hearing on Defendant's coram nobis petition, the circuit court denied the petition. The Supreme Court affirmed, holding (1) Defendant's claims of trial error were unavailing; and (2) the circuit court did not err in denying Defendant's petition for writ of error coram nobis. View "Bragg v. State" on Justia Law