Justia Civil Rights Opinion Summaries

Appellants, current and retired members of the Arkansas judiciary, contested the forfeiture provisions found in Ark. Code Ann. 24-8-215 and 24-8-710 that pertain to the Arkansas Judicial Retirement System. Appellants alleged that they wish or wished to seek reelection but that they elected not to because they had reached the age that continued service would result in the forfeiture of their retirement benefits. As relief, Appellants sought an injunction to prohibit the enforcement of the statutes. The circuit court granted summary judgment against Appellants. The Supreme Court affirmed, holding (1) the statutes do not violate amendment 80 to the Arkansas Constitution; (2) the forfeiture provisions of the statues do not offend the equal protection clauses of the United States and Arkansas Constitutions; and (3) Appellants’ remaining arguments were without merit. View "Landers v. Stone" on Justia Law

Appellees were prisoners under sentences of death for capital murder. Appellees filed an amended complaint against the Arkansas Department of Correction (ADC) challenging the constitutionality of Act 1096 of 2015, which establishes the current method by which executions are to be conducted in Arkansas. The circuit court granted summary judgment in part to ADC but denied ADC summary judgment on Appellees’ substantive due-process claim and cruel-or-unusual-punishment claim, concluding that these issues could not be decided as a matter of law because material questions of fact remained in dispute. ADC appealed, arguing that Appellees failed sufficiently to plead and prove the alleged constitutional violations in order to overcome ADC’s defense of sovereign immunity. The Supreme Court reversed and dismissed Appellees’ amended complaint, holding that the Act does not offend the Constitution. View "Kelley v. Johnson" on Justia Law

After a jury trial, Defendant was convicted of rape. Defendant was sentenced to a term of imprisonment of twenty-five years. Defendant filed a petition for postconviction relief, alleging ineffective assistance of counsel. Specifically, Defendant contended that his trial counsel erroneously informed him regarding his parole eligibility under a plea offer, and, as a result, he rejected the plea offer and went to trial, where he received a less favorable outcome. The circuit court denied Defendant’s petition. The Supreme Court reversed, holding that the circuit court’s findings were clearly erroneous. Remanded. View "Beavers v. State" on Justia Law

Eugene Butler brought this suit against the Board of Trustees of the University of Arkansas, alleging that the University violated the Arkansas Whistle-Blower Act (AWBA) upon terminating Appellant from his job as a police officer at the University of Arkansas at Pine Bluff. The University filed a motion to dismiss pursuant to Ark. R. Civ. P. 12(b)(6), arguing that Butler’s complaint failed to state a cause of action that was not barred by sovereign immunity. The circuit court denied the motion. The Supreme Court reversed and dismissed the complaint, holding that the University was entitled to sovereign immunity because the complaint failed to state a factual basis for Butler’s claim under the AWBA. View "Johnson v. Butler" on Justia Law

Appellant filed a request for documents related to his criminal case under the Freedom of Information Act. Appellee, the custodian of records for the Arkansas State Crime Laboratory, denied the request on the grounds that Appellant was an inmate incarcerated in the Arkansas Department of Correction. Thereafter, Appellant sought a hearing before the circuit court and filed a petition to proceed in forma pauperis. The circuit court initially granted the petition but later revoked Appellant’s pauper status and dismissed the case without prejudice, finding that three federal lawsuits should be counted as strikes under Ark. Code Ann. 16-68-607. The Supreme Court reversed, holding that the circuit court erred in counting as strikes cases Appellant filed in federal district court. Remanded. View "Hill v. Gallagher" on Justia Law

After a jury trial, Appellant was found guilty of second-degree battery and of being a felon in possession of a firearm. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court ultimately concluded that Appellant’s claims were not supported by the record. The Supreme Court affirmed, holding (1) the trial court did not clearly err when it denied Appellant’s petition without conducting an evidentiary hearing; and (2) the trial court did not clearly err in concluding that counsel did not provide ineffective assistance. View "Russell v. State" on Justia Law

Daniel Wren requested from The Arkansas State Police (ASP) unredacted access to certain accident reports under the Freedom of Information Act (FOIA). ASP contended that its policy of redacting personal information from accident reports was permitted under FOIA because disclosure is prohibited by the federal Driver’s Privacy Protection Act (DPPA). The circuit court ruled in favor of Wren and enjoined the policy of the ASP regarding redactions of accident reports. The Supreme Court Affirmed, holding that the DPPA does not prohibit disclosure of personal information in accident reports, which are public records within the meaning of FOIA. View "Ark. State Police v. Wren" on Justia Law

After a jury trial, Appellant was convicted of possession of methamphetamine, being a felon in possession of a firearm, and simultaneous possession of drugs and firearms. The court of appeals affirmed Appellant’s convictions and sentences. Appellant subsequently filed a timely postconviction petition alleging that the trial court was biased and that his two attorneys failed effectively to represent him. The trial court denied relief. The Supreme Court affirmed, holding (1) under Strickland v. Washington, Appellant failed to establish that he was prejudiced by his attorneys’ performance; and (2) the trial court did not err when it denied Appellant’s claim for postconviction relief without holding an evidentiary hearing. View "Stover v. State" on Justia Law

After a jury trial, Defendant was convicted of rape. Defendant was sentenced to ten years in prison. The court of appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief arguing that he received ineffective assistance of counsel because his defense counsel failed to object to testimony that allegedly bolstered the victim’s credibility. The circuit court denied Defendant’s claim, concluding that defense counsel’s failure to object was based on trial strategy and that his performance was not deficient. The Supreme Court affirmed, holding that the circuit court did not err in finding that counsel’s failure to object was based on trial strategy. View "Fukunaga v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of rape. Appellant was sentenced to consecutive terms of imprisonment of life, fifty years, and fifty years. Appellant appealed, contending that the trial court committed a speedy trial violation and did not follow the strict dictates of Ark. R. Crim. P. 28.3(b)(1). The Supreme Court affirmed, holding that Appellant’s trial date was well within the one-year period for a speedy trial, as the State met its burden to prove that any delay was excludable for speedy-trial purposes, and therefore, there was no speedy-trial violation in this case. View "Carter v. State" on Justia Law