Justia Civil Rights Opinion Summaries

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC) at a facility in Lincoln County, filed a pro se petition for writ of habeas corpus in the Pulaski County Circuit Court. Thereafter, Appellant filed a motion to dismiss the habeas petition and filed a second petition for habeas corpus. Appellant subsequently filed a series of motions and pleadings in the case. The circuit court dismissed the first habeas petition, denied the second habeas petition, and denied or dismissed motions and pleadings filed in the habeas proceeding. The Supreme Court dismissed Appellant's appeal and held the motion related to the appeal moot, holding that because Appellant was not incarcerated in Pulaski County, the Pulaski County Circuit Court did not have jurisdiction to release Appellant on a writ of habeas corpus. View "Pitts v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree sexual assault and sexual indecency with a child. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus seeking to challenge the calculation of his parole eligibility. The circuit court dismissed the petition. Appellant appealed and filed a pleading arguing that his sentence should be dismissed as unconstitutional on the ground that the trial judge did not follow federal sentencing guidelines. Appellant also argued that the circuit court lacked jurisdiction and that he was being held pursuant to an invalid conviction. The Supreme Court dismissed the motion and affirmed the circuit court's order, holding that Appellant failed to show he was entitled to declaratory judgment or a writ of mandamus, and his motion was without merit. View "Pitts v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of the rape of his stepdaughter and sentenced to 156 months' 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 that his counsel provided ineffective assistance, for, among other things, deciding not to introduce a recording into evidence for the purpose of impeaching the victim. The trial court found that Appellant was not entitled to relief on the allegation because Appellant failed to identify specific evidence that would have changed the outcome of the trial and because the introduction of evidence is a matter of trial strategy. The Supreme Court reversed the trial court on this point and remanded for an evidentiary hearing, as it was not apparent from the face of the petition or the record that Appellant was not entitled to relief on this allegation. View "Lemaster v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder for the death of his twenty-three-month-old son and sentenced to life imprisonment without parole. On appeal, Appellant argued that the circuit court erred by removing a juror without justification. The juror had spoken with prospective witnesses during trial proceedings and denied to the court that she had spoken with any witnesses. The circuit court removed the juror and replaced her by an alternate juror. The Supreme Court affirmed the conviction and sentence, holding that the circuit court did not abuse its discretion in removing the juror and seating an alternate. View "Ingram v. State" on Justia Law

After a jury trial, Appellant was convicted of failing to comply with registration and reporting requirements applicable to sex offenders and with residing within 2000 feet of a daycare facility as a level-4 sex offender. Appellant later filed a petition for postconviction relief, raising a number of claims stemming from the State's introduction of a risk assessment and offender profile report into evidence during the sentencing phase at trial and alleging that counsel was ineffective for several reasons. The trial court denied the petition without a hearing. The Supreme Court affirmed and held the motions related to the appeal moot, holding that because the record demonstrated that Appellant's petition did not set forth any meritorious claim under Ark. R. Crim. P. 37.1, the trial court did not err in dismissing the petition without a hearing. View "Green v. State" on Justia Law

After a jury trial, Appellant was convicted of the offense of being a felon in possession of a firearm and was sentenced as a habitual offender to a term of imprisonment. Appellant later filed an amended pro se petition for writ of habeas corpus contending that the convictions for the underlying felonies to the charge of being a felon in possession of a firearm were illegally obtained and that the evidence was insufficient to sustain the convictions for the underlying felonies. The circuit court dismissed the habeas petition. The Supreme Court dismissed Appellant's appeal and held Appellant's motion for extension of time to file his brief-in-chief moot, holding that Petitioner failed to raise a claim within the purview of a habeas action and therefore failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Glaze v. Hobbs" on Justia Law

Appellant entered a negotiated plea of guilty to rape. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging that his guilty plea was coerced and that the prosecution did not provide him with a videotape of an interview with the victim in violation of Brady v. Maryland. The circuit court denied the petition after a hearing. The Supreme Court dismissed Appellant's appeal and held his pro se motion for extension of time to file his brief moot, holding (1) Appellant's first claim did not rise to the level of coercion required to demonstrate that a writ of error coram nobis should issue; and (2) Appellant was not entitled to relief on his second claim because he failed to provide any factual support for the claim. View "Demeyer v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and second-degree sexual assault and sentenced as a habitual offender to an aggregate term of 960 months' imprisonment. After Appellant's conviction was affirmed on appeal, Appellant filed a pro se petition for postconviction relief alleging that his counsel was ineffective for several reasons, including for failing to challenge the constitutionality of Arkansas's rape-shield statute. The trial court denied the petition. The Supreme Court dismissed Appellant's appeal and held Appellant's motion for extension of time moot, holding that the circuit court did not err in denying Appellant's request for postconviction relief. View "Clayton v. State" on Justia Law

After a jury trial, Defendant was convicted of three counts of rape and sentenced to an aggregate sentence of 900 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a petition for postconviction relief, which was denied. Petitioner then filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court in order that he may proceed with a petition for writ of error coram nobis, contending that the prosecution withheld recorded statements of the victim in which she gave different accounts of the same event in violation of Brady v. Maryland. The Supreme Court denied the petition because Petitioner failed to offer any facts to substantiate his claim that the alleged recordings were concealed from the defense and that the victim gave conflicting statements to law enforcement. View "Charland v. State" on Justia Law

After Appellant was arrested for delivery of a controlled substance, the police department confiscated Appellant's car and some cash. The State filed an in rem civil action for the forfeiture of $129 and the car but later moved to dismiss the car from the action due to the vehicle being returned to the registered owner and the cash due to the currency being returned to Appellant. The trial court granted the motion. Appellant subsequently filed a writ of replevin with regard to the car and assorted other items. The trial court dismissed the replevin action, concluding that the State had no property in its possession belonging to Appellant and that all confiscated property had been returned to the proper owners. The Supreme Court dismissed Appellant's appeal because Appellant failed to meet his burden of producing a record demonstrating error. View "Wilson v. State" on Justia Law