Justia Civil Rights Opinion Summaries

After a second jury trial in 2012, Appellant was convicted of four counts of capital murder and one count of kidnapping. Appellant was sentenced to four terms of life imprisonment without the possibility of parole for the capital-murder convictions. Appellant's original convictions and sentences were reversed and remanded by the Supreme Court based on the circuit court's error in allowing the State to present reputation and other bad-acts evidence. The Supreme Court affirmed Appellant's 2012 convictions and sentences, holding, among other things, that the circuit court did not prejudicially err when it (1) denied Appellant's motion for directed verdicts for capital murder and kidnapping; (2) admitted out-of-court statements made by Appellant's son; (3) denied Appellant's motion for mistrial; (4) gave jury instructions on accomplice liability; (5) denied Appellant's challenge to a certain juror for cause; (6) failed to rule on Appellant's motion to settle the record; and (7) amended its judgment-and-sentencing order. View "Green v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a pro se civil-rights action against Appellees, two ADC officers, pursuant to 42 U.S.C. 1983, alleging use of excessive force and failure to protect as well as abuse of authority. Appellant also alleged state-law claims of assault and battery and negligence. The trial court dismissed the case on the basis that the claims were barred by the statute of limitations and immunity. The Supreme Court affirmed, holding that Appellant's claims were barred by the statute of limitations, and therefore, it was unnecessary to reach the issue of immunity or to address Appellant's remaining points on appeal. View "Early v. Baker" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery and theft of property. No appeal was taken. Appellant later filed a pro se petition for writ of error coram nobis, alleging that the trial court erred in declining to grant a continuance, to consider certain proof that Appellant was mentally deficient, to admit certain evidence at trial, and to suspend proceedings so a psychological evaluation could be conducted on Appellant. The trial court court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that because Appellant did not raise a claim within the scope of a coram-nobis proceeding, the trial court did not err in denying the petition. View "Croston v. State" on Justia Law

Appellant entered a negotiated plea of guilty or nolo contendere to rape. Appellant later filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, claiming that scientific evidence was available to show his actual innocence and that his arrest was illegal. The trial court denied the motion, finding that the petition was untimely and that Appellant offered no scientific evidence in support of his allegation. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding (1) considering Appellant's unsubstantiated claim that merely alleged the availability of scientific evidence, the trial court did not err in denying relief; and (2) dismissal of the petition was proper because it was not timely filed. View "Winnett v. State" on Justia Law

After a jury trial, Appellant was convicted of drug-related offenses. Appellant was sentenced to an aggregate term of life imprisonment. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging, among other things, that the judgment violated the prohibition against double jeopardy and that he was denied the effective assistance of counsel, his right to a speedy trial, and the right to conduct his own defense. The circuit court denied the petition. The Supreme Court dismissed appeal and mooted Appellant's motions related to the appeal, holding that none of Appellant's claims were grounds for issuance for the writ. View "Watts v. State" on Justia Law

Appellant entered a negotiated plea of guilty to robbery and overdraft. The circuit court sentenced Appellant to 300 months' imprisonment to run consecutive to his parole violation. Appellant appealed and filed motions for transcript and for extension of time to file brief. Appellant subsequently filed a pro se petition to correct an illegal sentence, which the circuit court denied as untimely. The Supreme Court dismissed the appeal and mooted the motions, holding (1) the claims raised in Appellant's petition did not allege an illegal type of sentence that was jurisdictional in nature, but rather made allegations that should have been raised at trial or in a timely petition pursuant to Ark. R. Crim. P. 37.1; and (2) Appellant's petition was also untimely under Ark. Code Ann. 16-90-111. View "Stanley v. State" on Justia Law

Petitioner was arrested in 2011 and detained in jail, where he remained since his arrest. Petitioner was later charged with aggravated robbery and capital murder. In 2013, Petitioner filed a second amended petition for writ of habeas corpus against the county sheriff, seeking his release from custody and asserting that his continued detainment violated his due process rights because the prosecutor announced there was insufficient evidence to move forward with the case. The Supreme Court denied the petition because none of the allegations raised by Petitioner called into question the trial court's jurisdiction or established that the commitment was invalid on its face. View "Smith v. Smith" on Justia Law

After a trial in the Saline County Circuit Court in 1987, Appellant was convicted of kidnapping and sentenced to 240 months' imprisonment. In 2013, Appellant filed a "motion to order release due to court order from 1996" in the circuit court in Lee County, where he was in custody. The circuit court denied the petition, concluding that it constituted a challenge to the judgment of conviction entered in the Saline County trial court and should have been filed there. The Supreme Court affirmed, holding that whether Appellant's motion was intended to be in the nature of a petition for writ of habeas corpus or a petition for postconviction relief, the circuit court was not wrong to dismiss the motion. View "Zulpo v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed on appeal. Prior to issuance of the mandate, Appellant filed a pro se petition for postconviction relief, alleging that his counsel had provided constitutionally deficient assistance for several reasons. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant's appeal and moot his motion for extension of time to file his brief because it was clear Appellant could not prevail if his appeal were permitted to go forward. View "Jordan v. State" on Justia Law

Petitioner filed a pro se petition for writ of habeas corpus in the circuit court in Lee County, where he was incarcerated. Thereafter, Petitioner was transferred to a facility in a different county. The circuit court dismissed Petitioner's petition. Petitioner filed a notice of appeal and moved to proceed with a belated appeal and to complete the record. The Supreme Court dismissed the motion for belated appeal and mooted the motion to complete the record, holding that because Petitioner was not in custody in the Lee County Circuit Court's jurisdiction, the Lee County Circuit Court did not retain personal jurisdiction over Petitioner and could no longer grant the relief sought. View "Fields v. State" on Justia Law