Justia Civil Rights Opinion Summaries

The State petitioned for an emergency stay of the Pulaski County Circuit Court’s order declaring unconstitutional Act 144 of 1997 and Amendment 83, which banned same-sex marriage. The State asserted that an emergency stay was necessary because circuit clerks were uncertain about whether they were required to issue marriage licenses to same-sex couples while the Supreme Court considered the State’s appeal. Appellees filed a motion to dismiss the State’s appeal because there was no final order in this case where the circuit court did not rule on the issue of injunctive relief or on the constitutionality of Ark. Code Ann. 9-11-208(b). The Supreme Court denied the State’s petition for an emergency stay and granted the motion to dismiss the State’s appeal, holding (1) the court’s order was not final, and therefore, the Supreme Court had no jurisdiction to hear the appeal; and (2) the circuit court’s order had no effect on Ark. Code Ann. 9-11-208(b) and its prohibition against circuit and county clerks issuing same-sex marriage licenses. View "Smith v. Wright" on Justia Law

After a jury trial, Appellant was found guilty of possession of a controlled substance and resisting arrest and was sentenced as a habitual offender to a term of imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel, prosecutorial misconduct, and due process violations. The circuit court denied the petition without a hearing. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s claims of ineffective assistance did not warrant relief because they were either refuted by the record of lacked factual substantiation; and (2) Appellant’s remaining claims were not cognizable in a Rule 37.1 proceeding. View "Rice v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and criminal use of a prohibited weapon. The Supreme Court affirmed. Appellant subsequently filed a request for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in denying relief, where Appellant failed to establish that his counsel was ineffective for failing to call certain witnesses, and the remainder of Appellant’s points on appeal were not preserved for the Court’s review. View "Pollard v. State" on Justia Law

After a jury trial in 1995, Appellee was convicted of capital murder and sentenced to mandatory life imprisonment without the possibility of parole. In 2013, Appellee filed a petition for writ of habeas corpus, asserting that his sentence to life imprisonment was illegal pursuant to Miller v. Alabama because he was a juvenile at the time of the offense. The circuit court granted Appellee’s petition and vacated Appellee’s sentence. The State appealed. The Supreme Court reversed, holding that because the circuit court did not make a finding of probable cause before it issued the writ, the case must be remanded for a determination of whether probable cause was shown to issue the writ. View "Hobbs v. Gordon" on Justia Law

Appellant, a registered voter, petitioned the circuit court for a declaratory judgment that Angela Byrd, a filed candidate for circuit judge, was unqualified and ineligible for that office because she was not a licensed attorney for a six-year time period immediately preceding the assumption of office for circuit judge. Specifically, Appellant alleged that Byrd failed to timely pay her annual bar license fee for the year 2014, and while her license was suspended, she was no longer licensed pursuant to Rule VII of the Arkansas Supreme Court’s Rules Governing Admission to the Bar. In response, Byrd filed a third-party complaint against the Clerk of the Supreme Court and Court of Appeals, alleging that Rule VII(C) was unconstitutional. The circuit court denied Williams’s petition and granted Byrd’s third-party complaint. The Supreme Court affirmed on the basis of Kelly v. Martin and Chandler v. Martin, concluding that Byrd was an eligible candidate for circuit judge. View "Williams v. Martin" on Justia Law

After a jury trial, Defendant was found guilty of capital murder. The conviction resulted in a sentence of life imprisonment without parole. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief, asserting that he had received ineffective assistance of counsel at trial and on direct appeal. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the circuit court did not err in ruling that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Watson v. State" on Justia Law

Appellant pleaded guilty to aggravated robbery and commercial burglary and was sentenced to an aggregate term of 240 months’ imprisonment. The court of appeals affirmed the sentence. Appellant subsequently filed a pro se petition for postconviction relief, asserting that his counsel provided ineffective assistance at trial and on direct appeal. The petition was denied. Appellant appealed and filed a motion to have his brief-in-chief duplicated at public expense. The Supreme Court dismissed the appeal and mooted the motion, holding that Appellant’s allegations of ineffective assistance of counsel were not sufficient to establish that he was entitled to postconviction relief. View "Thomas v. State" on Justia Law

After a jury trial in 1977, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. Appellant was sixteen years old at the time of the offense. In 2013, Appellant filed a petition for writ of habeas corpus, asserting that, in accordance with Miller v. Alabama, his life sentence was invalid on its face because the sentencer did not hold a hearing to consider mitigating factors relating to his youth before imposing the maximum sentence of life imprisonment. The petition was denied. The Supreme Court affirmed, holding that Miller was inapplicable to Appellant’s case because Appellant’s 1977 sentence to life imprisonment for first-degree murder was not mandatory and the sentencer was permitted to consider sentencing-related mitigating evidence. View "Smith v. State" on Justia Law

After the Pulaski County Humane Society (PCHS) seized many dogs from Defendant’s premises, Defendant was charged with three felony counts of aggravated cruelty to animals and ten misdemeanor counts of cruelty to animals for keeping her dogs without access to shade in excessively hot temperatures. The jury found Defendant guilty of five misdemeanor counts of cruelty to animals. The circuit court sentenced Defendant to 100 hours of community service and payment of a $500 fine. In a supplemental order, the court ordered Defendant to pay costs to PCHS of $6,425 and divested Defendant of custody of the five dogs that she had been convicted of abusing. Defendant appealed, arguing, inter alia, that the circuit court erred in denying her motion to suppress the evidence related to the seizure of the dogs. The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to suppress evidence but dismissed Defendant’s appeal and the State’s cross-appeal of the circuit court’s supplemental order, holding (1) the circuit court did not clearly err in denying Defendant’s motion to suppress; but (2) the circuit court lacked jurisdiction to decide the State’s petition for divestment and Defendant’s petition for custody of the dogs. View "Nance v. State" on Justia Law

After a jury trial, Appellant was convicted of possession of a controlled substance with intent to deliver and sentenced, as a habitual offender, to life imprisonment. After the Supreme Court affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37, alleging that his trial counsel provided ineffective assistance. The circuit court denied relief without a hearing. The Supreme Court reversed, holding that the circuit court erred (1) in relying on email correspondence that was attached to the prosecutor’s response to Appellant’s petition and was not part of the file, record, or petition; and (2) in denying Appellant’s petition in the absence of a hearing because the files and records did not conclusively show that Appellant was entitled to no relief. View "Guevara v. State" on Justia Law