The Arkansas Supreme Court affirmed the denial of postconviction relief for Chris Allen Oliger, who appealed his murder conviction pro se, claiming ineffective assistance of counsel and prosecutorial misconduct in a case involving alleged suppressed laptop evidence.
In an opinion delivered Feb. 12, 2026, Associate Justice Cody Hiland wrote for the court in *Chris Allen Oliger v. State of Arkansas* (Ark. 2026), affirming the Johnson County Circuit Court's denial and dismissal of Oliger's petition for postconviction relief filed under Arkansas Rule of Criminal Procedure 37.1.
Oliger, representing himself on appeal, raised three primary claims in his postconviction petition. First, he alleged ineffective assistance of counsel, claiming his trial attorney failed to adequately investigate the contents of a laptop computer and unidentified DNA evidence found on a knife at the crime scene. Second, Oliger raised a Brady violation claim, alleging the prosecutor suppressed a laptop that contained an exculpatory recording. Third, he claimed the prosecutor knowingly presented false testimony during his trial.
The Brady claim, named after the Supreme Court's 1963 decision in *Brady v. Maryland*, requires prosecutors to disclose evidence that is favorable to the defense and material to guilt or punishment. Violations of this constitutional duty can result in overturned convictions when the suppressed evidence would have affected the outcome of the trial.
According to the Arkansas Supreme Court's opinion, the Johnson County Circuit Court, presided over by Judge James Dunham, entered a detailed order addressing each of Oliger's postconviction claims before denying and dismissing the petition. The circuit court's analysis apparently found the claims lacked merit, leading to the dismissal.
On appeal to the Arkansas Supreme Court, Oliger raised the same three claims that were presented to the trial court. However, the high court found his arguments were "without merit" and affirmed the lower court's decision.
The case highlights several important aspects of postconviction relief proceedings in Arkansas. Rule 37.1 petitions allow defendants to challenge their convictions based on constitutional violations that may not have been apparent during the original trial proceedings. These petitions often involve claims of ineffective assistance of counsel, prosecutorial misconduct, or newly discovered evidence.
Ineffective assistance of counsel claims require defendants to demonstrate that their attorney's performance fell below an objective standard of reasonableness and that this deficient performance prejudiced the defense. Courts apply the two-pronged test established in *Strickland v. Washington*, requiring both deficient performance and resulting prejudice.
Brady violations, meanwhile, require three elements: the evidence must be favorable to the accused, either because it is exculpatory or because it is impeaching; the evidence must have been suppressed by the state, either willfully or inadvertently; and prejudice must have ensued, meaning the evidence was material to guilt or punishment.
The mention of DNA evidence on a knife at the crime scene suggests this was a violent crime case, though the opinion excerpt does not provide details about the underlying murder charges or conviction. The reference to unidentified DNA indicates there may have been forensic evidence that did not match Oliger, potentially supporting his claims of innocence or raising questions about alternative perpetrators.
The laptop computer appears central to Oliger's claims, with allegations that both his trial counsel failed to properly investigate its contents and that prosecutors improperly withheld it from the defense. The claim that the laptop contained an "exculpatory recording" suggests it may have contained evidence that could have supported Oliger's defense or contradicted the prosecution's case.
Pro se representation, where defendants represent themselves without counsel, presents additional challenges in appellate proceedings. Self-represented litigants must navigate complex procedural requirements and legal standards while arguing their own cases. Courts generally hold pro se litigants to the same standards as attorneys, though they may provide some leeway in interpreting filings.
The affirmance by the Arkansas Supreme Court indicates the justices found no reversible error in the circuit court's handling of the postconviction petition. This suggests either that Oliger's claims were procedurally defective, factually unsupported, or legally insufficient to warrant relief under Arkansas law.
Postconviction relief represents an important safeguard in the criminal justice system, allowing defendants to challenge convictions based on constitutional violations or newly discovered evidence. However, these petitions face high legal standards and procedural hurdles, as courts balance the finality of criminal judgments against the need to correct fundamental errors.
The case number CR-25-359 indicates this appeal was filed in 2025, suggesting Oliger's original conviction occurred some time before his postconviction petition. The underlying case number 36CR-21-455 suggests the original prosecution began in 2021 in Johnson County.
With the Arkansas Supreme Court's affirmance, Oliger's state court remedies appear exhausted, though he may potentially pursue federal habeas corpus relief depending on the specific circumstances and timing of his case.