Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of premeditated and deliberate capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in refusing to allow defense counsel to impeach a State witness with his prior acts of untruthfulness; (2) the circuit court did not abuse its discretion when it prevented Appellant from impeaching the sole eyewitness with his prior inconsistent statements; (3) the circuit court did not err in denying Appellant’s motion for mistrial based on discovery violations; (4) the overlap of the capital murder and first-degree murder statutes does not violate the Arkansas Constitution; (5) the circuit court’s statements revealing irritation of defense counsel’s tactics did not warrant reversal; and (6) Appellant’s argument that the circuit court abused its discretion in failing to conduct a Daubert hearing before admitting expert testimony about a palm print found at the scene of the murder and identified as Appellant’s was precluded from review. View "Maiden v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery and commercial burglary and sentenced to an aggregate term of 240 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance and that the evidence was insufficient to sustain the convictions. The trial court denied the petition. The Supreme Court dismissed the appeal and mooted the motion Appellant filed in relation to the appeal, holding that the trial court did not clearly err in concluding that trial counsel’s performance was not ineffective. View "Thomas v. State" on Justia Law

Appellant entered a negotiated plea of guilty to first-degree murder and possession of firearms by a certain person and was sentenced as a habitual offender to an aggregate term of 420 months’ imprisonment. Appellant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court denied relief without a hearing. The Supreme Court dismissed the appeal and mooted the motion filed in relation to the appeal, holding that Appellant failed to meet his burden of proving prejudice from any deficient performance on the part of trial counsel. View "Robinson v. State" on Justia Law

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC), filed a complaint against current or former members of the ADC, alleging violations of his civil rights, “failure to protect,” and assault, battery, and negligence. The circuit court dismissed Appellant’s complaint with prejudice, concluding that Appellant’s claims were barred by the doctrine of sovereign immunity and statutory immunity. The Supreme Court affirmed in part and reversed and remanded in part, holding that the circuit court (1) did not err in granting summary judgment to Appellees on Appellant’s claim under 42 U.S.C. 1983 against them in their official capacities in light of Appellant’s request for declaratory and injunctive relief; (2) erred in granting summary judgment to Appellees on Appellant’s failure-to-protect claim under 42 U.S.C. 1983 against Appellees in their individual capacities; and (3) did not err in granting Appellees summary judgment on Appellant’s negligence claim brought against Appellees in their individual capacities. View "Early v. Crockett" on Justia Law

After a jury trial, Appellant was found guilty of several drug-related charges. Appellant was sentenced to an aggregate term of 708 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus challenging the validity of two of his convictions and sentences. Specifically, Appellant argued that his convictions and sentences for the charges of possession of methamphetamine and manufacturing methamphetamine violated the constitutional prohibition against double jeopardy because one offense was a lesser-included offense of the other. The Supreme Court affirmed, holding that Appellant’s double jeopardy rights were not violated in this case because his convictions for the two charges did not arise from the same conduct. View "Bryant v. Hobbs" on Justia Law

Defendant was charged with sexual assault in the third degree and sexual assault in the fourth degree for engaging in sexual intercourse and having sexual contact with an inmate while Defendant was employed at the Arkansas Department of Correction. Defendant filed a motion to suppress, arguing that statements he had made in a recorded interview as part of the application process to be a state trooper had been made involuntarily and without his having been advised of his Miranda rights. The circuit court granted Defendant’s motion. The State brought an interlocutory appeal. The Supreme Court dismissed the interlocutory appeal because the correct and uniform administration of justice was not at issue. View "State v. Wright" on Justia Law

Appellant was charged with capital murder and residential burglary in the stabbing death of his former girlfriend. After a jury trial, Appellant was convicted as charged and sentenced to death for the murder conviction. Appellant filed a petition and amended petition for postconviction relief, arguing that his trial counsel was ineffective for several reasons. Following a hearing, the circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to show that his trial counsel’s performance fell below and objective standard of reasonableness or that his performance so prejudiced Appellant’s defense as to deprive him a fair trial. View "Marcyniuk v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of capital murder and sentenced to death. After the Supreme Court affirmed the conviction and sentence, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, asserting twenty-three allegations of ineffective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant’s petition, as Appellant did not receive ineffective assistance of counsel in either the guilt phase or sentencing phase of his trial. View "Wertz v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated residential burglary, first-degree battery committed in the presence of a child, and having employed a firearm in the aggravated burglary. The court of appeals affirmed. Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. Appellant subsequently filed a motion for an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and mooted the motion, holding that Appellant’s counsel provided constitutionally effective assistance at trial. View "Caery v. State" on Justia Law

Doralee Chandler, a registered voter, filed an amended petition for issuance of a writ of mandamus and for declaratory judgment, alleging that Judge Harrison G. Foster II was not a qualified or eligible candidate for circuit judge because he was not a “licensed attorney” for the constitutionally mandated six-year time period preceding the assumption of the office. The circuit court denied Chandler’s petition and granted Foster’s third-party complaint, determining (1) Foster was not “unlicensed” pursuant to Rule VII(C) of the Rules Governing Admission to the Bar despite his failure to timely pay his licensing fee four of the six consecutive years prior to the time for taking office, if elected; (2) the suspension of Foster’s license to practice law due to Foster’s failure to timely renew his licensing fee violated his due process rights; and (3) Rule VII(C) was unconstitutional. The Supreme Court affirmed, holding (1) the circuit court did not err in determining that Foster was not “unlicensed” pursuant to Rule VII and in finding that he was qualified to seek the position of circuit judge; and (2) Rule VII(C) is unconstitutional in that it provides for an automatic suspension of a lawyer’s license without procedural due process. View "Chandler v. Martin" on Justia Law