Justia Civil Rights Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally. Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court awarding attorney's fees to Allen Hargis following the division of Allen's military retirement account after the divorce of Allen and Lynn Harris, holding that the circuit court did not abuse its discretion by failing to conduct a hearing on the parties' respective financial abilities prior to awarding attorney's fees. After resolving the parties' dispute over the division of Allen's military retirement account following their divorce the circuit court awarded attorney's fees to Allen. On appeal, Lynn argued that the circuit court's failure to conduct a hearing prior to awarding attorney's fees infringed on her right to procedural due process under the Fourteenth Amendment. The Supreme Court affirmed, holding that the circuit court was not obligated to conduct an evidentiary hearing under the Fourteenth Amendment and that Lynn was not denied an opportunity to be heard on Allen's motion for attorney's fees. View "Hargis v. Hargis" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first degree murder, attempted first-degree murder, and a firearm enhancement, holding that the circuit court did not err in denying Defendant's motion for a mistrial. On appeal, Defendant argued that his constitutional rights were violated during his cross-examination of a witness when that witness testified regarding Defendant's right to remain silent.The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling the objection to the testimony because the comment was not the type of comment prohibited by the United States Supreme Court in Doyle v. Ohio, 426 U.S. 610, 618 (1976). View "Sirkaneo v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief alleging ineffective assistance of trial and appellate counsel, holding that Petitioner's allegations were unavailing. Petitioner was convicted of first-degree felony murder, aggravated robbery, felony theft, and misdemeanor theft. The Supreme Court reversed the aggravated robbery convictions and remanded for resentencing. After resentencing, Petitioner petitioned for postconviction relief under Ark. R. Civ. P. 37, alleging that he received constitutionally deficient counsel both at trial and on direct appeal. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Petitioner's alleged errors with respect to trial counsel's performance and that Petitioner's claims of ineffective assistance of appellate counsel were without merit. View "Thompson v. State" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Appellant's claims for postconviction relief that were raised pursuant to Ark. R. Crim. P. 37.1, holding that Appellant raised claims that were not cognizable in Rule 37.1 proceedings and failed to establish prejudice as a basis to support his ineffective assistance of counsel claims. Appellant was convicted of murder in the first degree and abuse of a corpse and sentenced as a habitual offender. Appellant filed a timely petition for Rule 37.1 relief, arguing that juror misconduct, prosecutorial misconduct, and an illegal search violated his right to due process and that he received ineffective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding (1) the only cognizable claims were the ineffective assistance of counsel claims that Appellant raised below and reasserted on appeal; and (2) the trial court did not clearly err when it found that Appellant had failed to demonstrate that he suffered prejudice as a result of his counsel's alleged errors. View "Williams v. State" on Justia Law

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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis filed by Petitioner, holding that Petitioner failed to state sufficient facts to establish a violation of Brady v. Maryland, 373 U.S. 83 (1963). Petitioner was convicted of robbery, theft of property, and employment of a firearm to commit aggravated robbery. In his coram nobis petition, Petitioner alleged that exculpatory testimony of two witnesses was suppressed in violation of Brady. The Supreme Court denied the petition, holding that Petitioner did not state facts that established a Brady violation but, instead, alleged ineffective assistance of counsel claims, which are not cognizable in coram nobis proceedings. View "Talley v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court granting summary judgment to Appellees and dismissing Appellant's civil rights claim, holding that the circuit court did not err in granting summary judgment in favor of Appellees. Appellant, an inmate in the Arkansas Department of Corrections (ADC), brought causes of action against Appellees, employees of the ADC, under 42 U.S.C. 1983, the Eighth Amendment, and Arkansas law. The circuit court granted summary judgment in favor of Appellees on the basis of qualified immunity. The Supreme Court reversed and remanded in part. On remand, the circuit court granted Appellees' motion for summary judgment, concluding that Appellees were entitled to qualified immunity. The Supreme Court affirmed, holding that Appellees, as state employees, were protected by qualified immunity. View "Early v. Crockett" on Justia Law

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The Supreme Court affirmed Defendant's conviction of capital murder, aggravated robbery, and a firearm enhancement, holding that there was no prejudicial error in the proceedings below. On appeal, Defendant argued that the circuit court erred in denying his motion to suppress his statements to police recorded in a police interrogation room and an alleged nonrecorded custodial statement made while police escorted him to a police car. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in rejecting Defendant's argument that the issuance of Miranda warnings was rendered ineffective; and (2) Defendant's remaining allegations of error were without merit. View "Pree v. State" on Justia Law

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The Supreme Court affirmed the decision of the Arkansas Department of Correction (ADC) denying Appellant's petition to proceed in forma pauperis in a civil action requesting judicial review, holding that Appellant failed sufficiently to raise a constitutional question. In his civil action, Appellant asserted that prison officials initiated and conducted disciplinary proceedings against him in violation of his constitutional rights. The circuit court concluded that Appellant failed to state a colorable cause of action and that ADC officials were entitled to sovereign immunity. The Supreme Court affirmed the circuit court's denial of Appellant's petition, holding that Appellant did not state sufficient allegations entitling him to judicial review of ADC's administrative procedures. View "Muntaqim v. Kelley" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for preliminary injunction, holding that the circuit court correctly concluded that Appellant failed to demonstrate a likelihood of success on the merits. Appellant was an inmate of the Arkansas Department of Correction (ADC) and a professed member of the Nation of Islam (NOI). Appellant filed the underlying suit against numerous ADC officials, alleging violations of the First Amendment and the federal Religious Land Use and Institutionalized Persons Act. Appellant moved for a preliminary junction against ADC's publications policy as applied to NOI material and against ADC's religious services policy so that he may lead NOI services in prison. The circuit court denied Appellant's motion for preliminary injunction, determining that Appellant failed to show irreparable harm and failed to demonstrate a likelihood of success on the merits. The Supreme Court affirmed, holding that the circuit court did not exceed its discretion in deciding not to issue a preliminary injunction. View "Muntaqim v. Lay" on Justia Law