Justia Civil Rights Opinion Summaries

A police officer stopped Defendant for driving with a defective passenger taillight. The officer subsequently arrested Defendant and charged him with driving while intoxicated (DWI), among other offenses. Defendant filed a motion to suppress, arguing that there was no probable cause for the initial traffic stop. The circuit court denied the motion, concluding that there was reasonable cause for the traffic stop. After a jury trial, Defendant was convicted of refusal to submit to a chemical test but was acquitted of the DWI charge. Defendant appealed the denial of his motion to suppress, arguing that because there is no Arkansas statute prohibiting a cracked taillight, the officer did not have probable cause to stop his vehicle. The Supreme Court affirmed, holding (1) the fact that Defendant’s taillight was visibly broken was sufficient probable cause to believe that he may have committed a traffic violation; and (2) therefore, the circuit court correctly concluded that there was probable cause for the officer to stop Defendant. View "Robinson v. State" on Justia Law

After a jury trial, Petitioner was convicted of aggravated assault on a family or household member, among other charges. The court of appeals reversed and remanded. On remand, Petitioner sought postconviction relief under Ark. R. Crim. P. 37, arguing that his counsel provided ineffective assistance. The circuit court denied Hayes’s petition. Petitioner appealed from that ruling and then filed a motion to reconsider. The Supreme Court affirmed, holding (1) if any of Petitioner’s allegations were not ruled on by the circuit court, his failure to seek a writ of mandamus barred further action; and (2) the circuit court did not err in finding that Petitioner was not prejudiced by any error on the part of trial counsel. View "Hayes v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. After the conviction was affirmed on appeal and Appellant unsuccessfully filed a petition for writ of habeas corpus, Appellant filed a second petition for habeas relief, alleging that his counsel provided ineffective assistance and that he was being illegally detained. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to provide any factual support for his allegations, and the circuit court did not err in failing to hold a hearing on the petition. View "Buchanan v. Hobbs" on Justia Law

In 2005, Appellant pleaded guilty to charges of theft by receiving, being a felon in possession of a firearm, and possession of a controlled substance with intent to deliver. Appellant received a ten-year suspended sentence on each count, but, in 2009, the trial court revoked Appellant’s suspended imposition of sentence for Appellant’s failure to meet the conditions under which the sentence was suspended. In 2013, Appellant filed a petition for writ of habeas corpus alleging that he was not afforded effective assistance of counsel when he entered his guilty plea and that the 2005 ten-year suspended imposition of sentence was an illegal sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish a basis for a writ of habeas corpus to issue. View "Murry v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of capital felony murder and sentenced to life imprisonment without the possibility of parole. After Appellant’s conviction was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that (1) some of Appellant’s claims were conclusory and raised for the first time on appeal and thus not subject to review; and (2) the remainder of Appellant’s claims of error were without merit. View "Dixon v. State" on Justia Law

Petitioner, an inmate, filed a pro se petition for writ of habeas corpus. The circuit court granted the petition in part and denied it in part. Petitioner did not timely appeal and subsequently sought leave to proceed with a belated appeal. In support of his motion to proceed with his belated appeal, Petitioner contended that, as a functional illiterate, it was impossible for him to comply with procedural rules. The Supreme Court denied Petitioner’s motion to proceed with the appeal, holding that it was the duty of Petitioner to file a timely notice of appeal, and Petitioner did not establish good cause for his failure to do so. View "Sillivan v. Hobbs" on Justia Law

Appellant pled guilty to several drug-related charges and received five years of supervised probation. Appellant later pled that he had violated the conditions of probation. After a hearing, the circuit court sentenced Appellant to ten years incarceration. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief, asserting that his counsel was ineffective for (1) failing to raise the issue that the revocation hearing had been held outside the sixty-day limitation set by statute, and (2) not asserting that Appellant did not receive adequate notice of the alleged probation violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in its judgment. View "Johnson v. State" on Justia Law

Appellant pleaded guilty to first-degree murder and was sentenced to 480 months’ imprisonment. Appellant later filed a pro se petition for writ of error coram nobis alleging that his guilty plea was coerced and that he was incompetent at the time of entering the plea. The circuit court denied relief. The Supreme Court dismissed Appellant’s appeal and mooted his motion for extension of time to file his brief-in-chief, holding (1) Appellant’s allegation that his guilty plea was coerced due to ineffective assistance of counsel was outside the purview of a coram-nobis proceeding; and (2) the issue of Appellant’s competency could have been raised at the time his plea was entered and was not a ground for proceeding with a petition for writ of error coram nobis. View "Harris v. State" on Justia Law

Appellant, an inmate incarcerated under a sentence of life imprisonment without parole, filed a pro se petition for writ of habeas corpus alleging four bases for issuance of the writ, including the allegation that his commitment was invalid on its face because he had been charged with and pleaded guilty to murder in the first degree and had been sentenced for capital-felony murder. The circuit court dismissed Appellant’s petition without a hearing. The Supreme Court affirmed, holding (1) Appellant was charged with a capital felony, which was punishment by life imprisonment without parole; and (2) therefore, Appellant was sentenced correctly, his judgment of conviction was not illegal on its face, and habeas relief was not warranted. View "Gooch v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of possession of methamphetamine with intent to deliver and other drug-related offenses. After Appellant’s convictions were affirmed on appeal, Appellant unsuccessfully filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and, subsequently, a pro se petition for writ of habeas corpus. Appellant later filed a second pro se petition for writ of habeas corpus. The circuit court denied the petition. The Supreme Court affirmed, holding (1) to the extent Appellant argued that he was entitled to habeas relief because the trial court lacked jurisdiction and the authority to sentence him, this claim was barred by the law-of-the-case doctrine; (2) the law-of-the-case doctrine also applied to Appellant’s challenge to his consecutive sentences; and (3) Appellant’s request for jail-time credit was not cognizable in a petition for writ of habeas corpus. View "Bumgarner v. Hobbs" on Justia Law