Roberts v. State

Summary

The Supreme Court of Arkansas held that the circuit court clearly erred in finding Karl D. Roberts competent to choose between life and death and to knowingly and intelligently waive postconviction relief. The court reversed and remanded for postconviction proceedings under Arkansas Rule of Criminal Procedure 37.5. The court also referred to the Committee on Criminal Practice the question whether postconviction review should be mandatory in capital cases.

Holdings

1. The circuit court's concise findings sufficiently specified the basis for its ruling and permitted meaningful appellate review under Rule 37.5(i).
2. A death-sentenced defendant may waive postconviction remedies only if judicially determined to have the capacity to understand the choice between life and death and to knowingly and intelligently waive the rights at issue.
3. The circuit court clearly erred in finding that Roberts was competent to waive postconviction review.
4. The court declined to extend mandatory appellate review to Rule 37.5 postconviction proceedings at this time, but referred the issue to the Committee on Criminal Practice for consideration.

Questions Presented

1. Whether the circuit court made sufficiently specific findings of fact and conclusions of law to permit meaningful appellate review under Arkansas Rule of Criminal Procedure 37.5(i).
2. Whether Roberts was competent to choose between life and death and knowingly and intelligently waive his postconviction remedies.
3. Whether Arkansas should require mandatory Rule 37.5 postconviction review in all capital cases notwithstanding a defendant's waiver.
4. Whether acceptance of Roberts's waiver violated the solid-footing doctrine.

Disposition

reversed_and_remanded