Articles Posted in Arkansas Supreme Court

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The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition for writ of error coram nobis in which Appellant alleged that the State violated Brady v. Maryland, 373 U.S. 83 (1963), suborned perjury, and breached the agreement he entered into with the State before entering a plea of guilty. The Supreme Court held (1) the trial court did not abuse its discretion by treating Appellant’s coram nobis petition as a petition raising claims of ineffective assistance of counsel; (2) Appellant did not demonstrate a Brady violation; (3) Appellant failed to establish that his plea was coerced; and (4) Appellant’s argument that he was actually innocent of the offense to which he pleaded guilty did not establish a ground for the writ. View "Williams v. State" on Justia Law

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The Supreme Court affirmed the trial court’s denial of Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1. Appellant was convicted of kidnapping, rape, and aggravated robbery and was sentenced to three terms of life imprisonment. The Supreme Court affirmed on appeal. Appellant then filed a pro se Rule 37.1 petition alleging multiple claims of ineffective assistance of counsel. The trial court denied relief. Appellant appealed. The Supreme Court affirmed, holding (1) there was no error in the denial of Appellant’s motion for new trial in regard to some claims; (2) another claim raised by Appellant was waived on appeal; and (3) Appellant’s claim with respect to the trial court’s order in denying his motion for a new trial was not cognizable in a Rule 37.1 proceeding. View "Sylvester v. State" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the circuit court’s order requiring the Arkansas Department of Correction (ADC) to provide Steven Shults with the pharmaceutical package inserts and labels for its supply of midazolam, one of the drugs in the State’s execution protocol. Shults filed a complaint against the ADC after it refused to provide him with public records pertaining to the State’s supply of midazolam pursuant to his Arkansas Freedom of Information Act request. The ADC refused to disclose the package inserts or labels for the midazolam, arguing that these documents could be used to identify the sellers or suppliers of the drug in violation of the Method of Execution Act (MEA), Ark. Code Ann. 5-4-617. On appeal, the Supreme Court held (1) the circuit court correctly determined that the identity of drug manufacturers is not protected under the confidentiality provisions of section 5-4-617; but (2) the circuit court erred in requiring disclosure of the unredacted records, as certain information was confidential under section 5-4-617(j). The court remanded the case for the circuit court to determine which information must be redacted on the midazolam labels and/or package inserts at issue. View "Arkansas Department of Correction v. Shults" on Justia Law

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The Supreme Court dismissed the State’s interlocutory appeal from the circuit court’s order granting Defendant’s motion to suppress. On appeal, the State argued that the circuit court erred (1) by interpreting Ark. R. Crim. P. 2.2 to invalidate the encounter between Defendant and the arresting officer, and (2) in concluding that the officer’s actions constituted a seizure. The Supreme Court held that this case was not properly before it under Ark. R. App. P.-Crim. 3 where this was a case involving the trial court’s consideration of the particular facts of the case and its determination that those facts did not provide reasonable suspicion for an investigatory stop under rule 3.1. View "State v. McWilliams" on Justia Law

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In Pavan v. Smith, 137 S. Ct. 2075 (2017), the United States Supreme Court held that Arkansas’s birth-certificate law, Ark. Code Ann. 20-18-401, is unconstitutional to the extent it treats similarly-situated same-sex couples differently from opposite-sex couples. The Court thus reversed the judgment of the Arkansas Supreme Court and remanded for further proceedings consistent with the opinion of the Court. The Arkansas Supreme Court reversed the order of the circuit court, which “impermissibly rewrote the statutory scheme” and remanded for entry of a final judgment consistent with the mandate of the United States Supreme Court. On remand, the circuit court should award such relief as necessary to ensure that same-sex spouses are afforded the same right as opposite-sex spouses to be listed on a child’s birth certificate in Arkansas, as required under Pavan v. Smith. View "Smith v. Pavan" on Justia Law

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The Supreme Court affirmed Defendant’s convictions for the kidnapping and murder of his girlfriend. A jury sentenced Defendant to life imprisonment without the possibility of parole for murder plus forty years imprisonment for kidnapping. In affirming the convictions on appeal, the Supreme Court held that the trial court did not err in denying Defendant’s challenges to the State’s use of three peremptory strikes against black potential jurors during jury selection because the State provided sufficient race-neutral explanations to justify its use of the peremptory strikes. View "Woods v. State" on Justia Law

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The Supreme Court reversed the circuit court’s grant of summary judgment in favor of Defendants in this illegal-exaction suit alleging that certain acts of 2015, which appropriate funds from the Arkansas General Improvement Fund to eight planning and development districts, are unconstitutional. Both parties appealed the circuit court’s rulings. The Supreme Court held (1) the circuit court correctly found that Plaintiff had taxpayer standing in this illegal-exaction suit; (2) Plaintiff’s appeal is not moot; and (3) the circuit court erred in granting summary judgment because the challenged acts violate article 5, section 29 of the Arkansas Constitution. View "Wilson v. Walther" on Justia Law

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The Supreme Court affirmed Appellant’s conviction for possession of a controlled substance with purpose to deliver, for which Appellant was sentenced to five years’ probation and ordered to pay a $5000 fine. The court held (1) the trial court did not err by denying Appellant’s motions for directed verdict; (2) the trial court did not err by failing to give Appellant’s proffered jury instruction regarding constructive possession; and (3) the trial court did not commit clear error in denying Appellant’s motion to suppress evidence seized as a result of a search. View "Pokatilov v. State" on Justia Law

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The Supreme Court affirmed the circuit court’s ruling that defense counsel was not ineffective for failing to dismiss the drug offense charges against Defendant based on a speedy-trial violation. The circuit court found that sufficient excludable time periods should be charged against Defendant such that no speedy-trial violation occurred. The Supreme Court agreed, holding that the circuit court did not err in finding that counsel’s failure to raise a speedy-trial argument was not deficient because there was no speedy-trial violation and that Defendant failed to meet the first prong of Strickland. View "Turner v. State" on Justia Law

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The Supreme Court affirmed the trial court’s conclusion that Appellant’s attempt to waive his right to counsel and represent himself at trial was equivocal and the court's decision to proceed with Appellant’s original counsel. After Appellant requested to waive his right to counsel and represent himself at trial, Appellant engaged in multiple instances of uncertainty while being told of the consequences of self-representation. Therefore, the trial court ruled that Appellant’s invocation was equivocal. The Supreme Court agreed, holding that Appellant’s attempt to waive counsel and self-represent was not sufficiently unequivocal. View "Reed v. State" on Justia Law