Justia Civil Rights Opinion Summaries

Appellant, an inmate, filed a complaint against twenty-two employees of the Arkansas Department of Corrections alleging violations of his civil rights. Specifically, Appellant claimed that he was denied access to certain religious publications and the right to lead Nation of Islam religious services. Appellant filed a pro se motion for a preliminary injunction, summary judgment, and default judgment seeking to enjoin Defendants from violating his rights. The circuit court denied the motion without holding a hearing on the merits. Appellant appealed the denial of his motion for summary judgment and a preliminary injunction. The Supreme Court (1) dismissed Appellant’s appeal from the motion for summary judgment, as a denial of a motion for summary judgment is not a final, appealable order; and (2) reversed and remanded to the circuit court to hold a hearing on Appellant’s motion for preliminary injunction, holding that, under the circumstances of this case, the complexity and the rights in question warranted a hearing below. View "Muntaqim v. Hobbs" on Justia Law

Appellant, an inmate, filed a petition seeking judicial review of a decision of the Arkansas Parole Board that denied Appellant’s application for parole. In his petition, Appellant contended that the Board had deprived him of liberty without due process and had retroactively applied a parole statute in violation of the ex-post-facto prohibition in the United States and Arkansas Constitutions. Appellant filed a petition to proceed in forma pauperis in connection with his petition for judicial review. The circuit court summarily denied Appellant’s petition to proceed in forma pauperis on the basis that Appellant had not stated a colorable claim. The Supreme Court affirmed in part, reversed in part, and remanded, holding that Appellant failed to state a colorable claim based on the allegation that the denial of his parole eligibility constituted a violation of his right to due process but did state sufficient non-conclusory facts to assert a colorable claim for judicial review of an alleged violation of the ex-post-facto prohibition, and therefore, Appellant was entitled to proceed in forma pauperis. View "Ruiz v. Felts" on Justia Law

Defendant, who was sixteen years old at the time of his arrest, was charged as an adult with robbery and aggravated assault. Defendant was subsequently interviewed by police in connection with an assault of a female. The day after he made a statement, Defendant was charged as an adult with residential burglary, sexual assault in the second degree, and aggravated assault. Defendant filed a motion to suppress the statement he made to police. The circuit court granted the motion to suppress, concluding that Defendant was unable to waive his right to counsel because he was in the custody of the Arkansas Department of Human Services at the time of the interview. The Supreme Court reversed, holding that the circuit court erred in its interpretation of Ark. Code Ann. 9-27-317(g) and therefore erred in granting Defendant’s motion to suppress. View "State v. Griffin" on Justia Law

At issue in this case was Ordinance 5781, entitled “An Ordinance To Ensure Uniform Nondiscrimination Protections Within The City of Fayetteville For Groups Already Protected To Varying Degrees Throughout State Law.” After the Fayetteville City Council passed the Ordinance, Appellants filed a complaint and a motion for declaratory judgment, arguing that Ordinance 5781 violates Act 137 of 2015, the Intrastate Commerce Improvement Act. Thereafter, the Ordinance was approved by voters in a special election. The circuit court concluded that the Ordinance did not violate Act 137. The Supreme Court reversed, holding that Ordinance 4781 violated the plain wording of Act 137 by extending discrimination laws in the City of Fayetteville to include two classifications not previously included under state law, thus creating a direct inconsistency between state and municipal law. View "Protect Fayetteville v. City of Fayetteville" on Justia Law

After a jury trial, Defendant was found guilty of second-degree sexual assault and rape. The Supreme Court affirmed the convictions. Thereafter, Defendant filed original and amended petitions for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting ineffective assistance of counsel. The trial court granted the original and amended petitions for postconviction relief, concluding that counsel provided ineffective assistance and that the court was unable to say that counsel’s failures did not affect the outcome of the sentencing phase. The Supreme Court reversed, holding that the trial court’s finding of prejudice was clearly erroneous. View "State v. Thompson" on Justia Law

Appellant, a parolee, was charged as a habitual criminal offender with simultaneous possession of drugs and a firearm, possession of methamphetamine with intent to deliver, and possession of drug paraphernalia. Appellant filed a motion to suppress the evidence seized during his arrest on the basis that officers entered his hotel room without a warrant and without knocking and announcing their presence. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the knock-and-announce rule applies to parolees, but the exclusionary rule is not the appropriate remedy; and (2) despite the knock-and-announce violation, the evidence seized from Appellant should not have been suppressed. View "Lane v. State" on Justia Law

Defendant pleaded guilty to charges from several different cases, including first-degree murder, aggravated robbery, and first-degree escape. Defendant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due to his counsel’s failure to request a competency hearing. The circuit court denied relief, concluding that trial counsel made a reasonable decision not to pursue the competency question further, and that decision did not prejudice Defendant. The Supreme Court affirmed, holding that Defendant did not satisfy the Strickland v. Washington test for ineffective-assistance-of-counsel claims under Rule 37.1. View "Beverage v. State" on Justia Law

After a jury trial, Appellant was found guilty of manslaughter. Appellant was sentenced to ten years’ imprisonment. The Supreme Court affirmed in part and reversed and remanded in part for a new trial, holding that the circuit court (1) did not err by excluding testimony about the victim’s character and previous acts of violence; (2) prejudicially erred by refusing to declare a mistrial when it was discovered that the court’s bailiff had barred members of Appellant’s family from the courtroom during voir dire; and (3) did not abuse its discretion by refusing to give instructions on negligent homicide and imperfect self-defense. View "Schnarr v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and first-degree battery. Defendant was sentenced to an aggregate sentence of sixty-five years’ imprisonment. The court of appeals affirmed. Thereafter, Defendant filed a petition for postconviction relief pursuant to Ark. R. Civ. P. 37.1, in which he asserted numerous claims of ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that the circuit court did not err in denying Defendant’s claims that his appellate counsel provided ineffective assistance and that his trial counsel provided ineffective assistance. View "Liggins v. State" on Justia Law

Appellees, three married female couples, filed suit against Appellant, the director of the Arkansas Department of Health, seeking a declaration that the refusal to issue birth certificates with the names of both spouses of the birth certificates of their respective minor children violated their equal protection and due process rights. Appellees also sought an order requiring Appellant to issue corrected birth certificates. The circuit court ordered Appellant to issue three amended birth certificates naming both spouses. The Supreme Court reversed, holding (1) the circuit court erred in finding that the case was controlled by Smith v. Wright; and (2) the circuit court erred in finding that Ark. Code Ann. 20-18-401(e) and (f) and Ark. Code Ann. 20-18-406(a)(2) facially violated Appellees’ rights to due process and equal protection. View "Smith v. Pavan" on Justia Law