Justia Civil Rights Opinion Summaries

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

After a jury trial, Appellant was found guilty of aggravated robbery and misdemeanor theft of property, with a firearm enhancement. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming that he was denied a fair and impartial trial, that his confession was the result of coercion by law enforcement, that his counsel provided ineffective assistance, and that the prosecutor committed misconduct during trial. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted the motions Appellant filed in relation to the appeal, holding that the petition was wholly without merit. View "Williams v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts rape and sentenced to four consecutive terms of 480 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging claims of trial error, insufficiency of the felony information, and due process and equal protection violations. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue, and therefore, the trial court did not err in denying the petition. View "Jones v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and sentenced as a habitual offender to life in prison without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his counsel had provided ineffective assistance. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal, denied Appellant’s motion to reinvest jurisdiction in the trial court, and mooted Appellant’s motions for appointment of counsel and to stay appeal, holding that Appellant’s allegations were conclusory or failed to provide a basis for a finding of ineffective assistance of counsel. View "Craigg v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and possessing matter depicting sexually explicit conduct involving a child. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, claiming that he was not afforded effective assistance of counsel. Following a hearing, the trial court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant’s ineffective assistance of counsel claims were either conclusory, not supported by the evidence, not cognizable in a Rule 37.1 proceeding, or without merit. View "Boatwright v. State" on Justia Law

Mike Burcham filed an action against the University of Arkansas and others, claiming that he was wrongfully terminated. The University filed an amended motion to dismiss, arguing that Burcham’s complaint was barred by sovereign immunity. The circuit court denied the motion, concluding that an allegation in Burcham’s complaint that the University failed to follow a grievance procedure outlined in the employee handbook was sufficient to waive the University’s sovereign immunity. The Supreme Court reversed, holding that none of the exceptions to sovereign immunity were applicable to the instant case, and therefore, the circuit court erred in denying the University’s amended motion to dismiss. View "Bd. of Trs. v. Burcham" on Justia Law

Petitioner pleaded guilty to two counts of second-degree sexual assault. Petitioner subsequently filed in the trial court a pro se petition for writ of error coram nobis alleging that his guilty plea was coerced and that newly discovered evidence warranted issuance of the writ. The circuit court denied the petition. Petitioner later sought leave to proceed with a belated appeal of the order. The Supreme Court denied the motion, holding that the trial court did not abuse its discretion in denying coram nobis relief where (1) Petitioner’s claims did not rise to the level of coercion required to demonstrate that a writ of error coram nobis should issue; and (2) the petition did not demonstrate a Brady violation in that there was no fact cited by Petitioner that could not have been known at the time the plea was entered. View "Bannister v. State" on Justia Law

In 1991, Appellant was convicted and sentenced to death for the murders of Charles and Nancy Brannon. The circuit court later vacated Appellant’s convictions and sentences, finding that the prosecution’s failure to reveal information about one of its witnesses prejudiced Appellant’s right to a fair trial. Appellant was retried for the murders in 2012, was against convicted of both counts of capital murder, and was sentenced to life without parole. The Supreme Court affirmed, holding that the circuit court did not err by (1) permitting Byron Hopes to testify because although his testimony was procured through an illegal sentence reduction, the proper remedy was cross-examination of the witness, not suppression of the testimony; (2) holding that the cross-examination of Hopes about the deal would open the door to testimony about Appellant's other murder case; (3) finding that transcripts of witness testimony from Appellant's first trial were admissible in his new trial; and (4) excluding part of the prior testimony of Bill Keeling, whose testimony was previously proffered but rejected in Appellant's first trial. View "Sanders v. State" on Justia Law

After a jury trial, Appellant was convicted of thirty-seven various sex offenses and sentenced to a total of thirty-seven years incarceration. After Appellant’s convictions were affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that his trial counsel was ineffective for because counsel was simultaneously representing Appellant and Appellant’s wife at the time of Appellant’s trial, and the dual representation created an actual conflict of interest adversely affecting counsel’s performance. The trial court ultimately denied the petition. The Supreme Court reversed, holding (1) an actual conflict of interest existed under the circumstances of this case; and (2) the actual conflict of interest adversely affected counsel’s performance. Remanded for a new trial with conflict-free counsel. View "Rackley v. State" on Justia Law