Justia Civil Rights Opinion Summaries

The Supreme Court reversed the circuit court’s grant of summary judgment and dismissal of Plaintiff’s civil rights and tort complaint on the ground of failure to exhaust administrative remedies.Plaintiff, an inmate incarcerated in the Arkansas Department of Correction (ADC), filed a complaint against ADC officials in their individual capacities under the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108. Plaintiff alleged that Defendants violated his due process rights when they failed timely to release him from punitive isolation and that Defendants committed the torts of false imprisonment, negligence, and excessive confinement. The circuit court found that Plaintiff had failed to exhaust his due process and tort claims as required by the Prison Litigation Reform Act (PRLA), 42 U.S.C. 1997e. Because the PRLA is a federal law that is not applicable to actions brought against public officials in their individual capacities under ACRA and Arkansas tort law, the circuit court erred in granting Defendants’ motion for summary judgment and dismissing Plaintiff’s case for failure to exhaust. View "Harmon v. Jackson" on Justia Law

The Supreme Court affirmed in part and reversed and dismissed in part the order of the circuit court denying Appellant’s petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5.The Court reversed and dismissed as to the issue of whether trial counsel’s failure to present the affirmative defense of not guilty by reason of mental disease or defect was ineffective assistance of counsel, holding that the trial court did not have jurisdiction to consider this issue. The Court otherwise affirmed, holding (1) the trial court did not err in finding that counsel did not provide ineffective assistance as to Appellant’s remaining allegations of defective representation; and (2) the cumulative error rule in allegations of ineffective assistance of counsel should not be recognized in Arkansas. View "Lacy v. State" on Justia Law

The Supreme Court denied Petitioner’s motion to reinvest jurisdiction in the trial court to consider a petition for a writ of audit querela, which the Court treated as a petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, or alternatively, for leave to file a postconviction petition in the trial court pursuant to Ark. R. Crim. P. 37.2(a). The Court held (1) Petitioner failed to raise sufficient allegations that established entitlement to relief under coram nobis; and (2) because Petitioner’s Rule 37.2 petition was filed outside the three-year statute of limitations, he was not entitled to relief unless his assertions would render the judgment void, and the adequacy of Miranda warnings does not implicate a fundamental right that is capable of voiding the judgment. View "Munnerlyn v. State" on Justia Law

The Supreme Court reversed Appellant’s convictions for negligent homicide, driving while intoxicated, and reckless driving, holding (1) because the refusal to submit to a blood test pursuant to Ark. Code Ann. 5-65-202 would result in the imposition of criminal penalties, as applied to Appellant, the statute is unconstitutional, and therefore, the circuit court clearly erred in finding that the blood draw from Appellant did not implicate the Fourth Amendment; and (2) the totality of the circumstances did not establish that Appellant either impliedly or voluntarily consented to the warrantless blood draw. View "Dortch v. State" on Justia Law

The Supreme Court reversed the trial court’s denial of Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not provide sufficient written findings to demonstrate that Appellant was not entitled to relief on his ineffective assistance claims. The trial court denied relief without conducting an evidentiary hearing. The Court remanded to the trial court with directions to conduct a postconviction hearing limited to the two claims of ineffective assistance of counsel preserved by Appellant in this appeal. View "Collins v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying, without a hearing, Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1. In his petition, Appellant alleged that his trial counsel provided ineffective assistance in multiple instances. The trial court disagreed. The Supreme Court affirmed, holding (1) Appellant failed to meet the two-prong analysis set forth in Strickland v. Washington, 466 U.S. 668 (1984) that his counsel’s performance was deficient and that the deficient performed prejudiced his defense; and (2) the circuit court did not err in denying the petition for postconviction relief without an evidentiary hearing. View "Gordon v. State" on Justia Law

In this capital murder case, the Supreme Court denied Appellant’s motion to recall this court’s mandate in Appellant’s direct appeal, holding that there was no breakdown in the appellate process that would warrant recalling the mandate.Appellant was convicted of capital murder and sentenced to death. The Supreme Court affirmed on direct appeal. Here, Appellant filed a motion to recall the mandate and stay his execution, arguing that he did not receive the minimum due-process requirements prescribed in Ake v. Oklahoma, 470 U.S. 68 (1985). Specifically, Appellant argued that the Supreme Court misapplied Ake, and therefore, he did not have access to an independent mental health expert to assist in his defense. The Supreme Court granted Appellant’s motion to stay his execution and took his motion to recall the mandate as a case. The court then denied the motion and lifted the stay of his execution, holding that because Appellant made the strategic decision not to pursue a partisan psychiatrist, there was not a “defect in the appellate process” that was attributable to this court upon its review. View "Davis v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court’s judgment and decree of foreclosure finding in favor of Bank and against Appellant on his counterclaims against Bank and his third-party complaint against the former vice president of commercial lending at Bank (“VP”). The court held (1) the circuit court erred in failing to submit Appellant’s legal counterclaims and third-party claims to the jury; (2) the circuit court erred in granting Bank and VP’s motion to strike Appellant’s jury trial demand based on a predispute jury-waiver clause contained in the loan agreement; and (3) Marvell Light & Ice Co. v. General Electric Co., 259 S.W. 741 (1924), is overruled to the extent that it holds that there is a per se new business rule preventing lost profits unless the business is an old business. View "Tilley v. Malvern National Bank" on Justia Law

The Supreme Court affirmed the circuit court’s dismissal of Appellant’s pro se civil complaint and amended complaint, which alleged that Appellees, acting under color of state law, had engaged discrimination in violation of the Arkansas Civil Rights Act of 1993, Ark. Code Ann. 16-123-101 to -108, engaged in a civil conspiracy, and committed the tort of outrage. The circuit court dismissed the complaint without prejudice based on the grounds set forth in Appellees’ motion to dismiss. The Supreme Court affirmed on the ground that the claims were barred by the statute of limitations and therefore did not reach the other grounds on which Appellant’s complaint was dismissed. View "Hutchinson v. Rutledge" on Justia Law

The Supreme Court affirmed the trial court’s denial of Appellant’s pro se petition and amended petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, in which Appellant raised multiple claims of ineffective assistance of counsel. The trial court conducted an evidentiary hearing and issued written findings on those issues it considered to have been raised during the course of the hearing. At that hearing, Appellant did not specifically reassert all the claims set forth in the petitions. On appeal, Appellant claimed that the trial court committed reversible error pursuant to Ark. R. Crim. P. 37.3(a) by failing to specifically all the claims raised in his petitions. The Supreme Court affirmed, holding (1) Appellant waived any issues he alleged should have been ruled on by the trial court; and (2) because Appellant failed to argue the merits of the claims on which the trial court ruled, those issues were considered abandoned. View "Brown v. State" on Justia Law