Justia Civil Rights Opinion Summaries

The Supreme Court dismissed the order of the circuit court denying Appellant's motion for new trial based on allegations of juror misconduct, holding that the motion was clearly untimely, and therefore, the circuit court did not have authority to act on Appellant's motion when it entered orders in this action.In 2004, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 2018, Appellant filed a petition for writ of habeas corpus and motion for new trial alleging juror misconduct. The trial judge dismissed the habeas petition without prejudice and denied the motion for new trial. The Supreme Court dismissed the appeal, holding that Appellant's motion for new trial was untimely, and the circuit court lacked jurisdiction to consider the motion. View "Herron v. Ark. Department of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's multiple claims of ineffective assistance of counsel, holding that the circuit court did not err on Appellant's seven separate claims of ineffective assistance of counsel.Appellant was convicted of second-degree murder and sentenced to life in prison. Appellant later filed a petition under Ark. R. Crim. P. 37 arguing that the circuit court erred on seven distinct allegations of ineffective assistance of counsel. The Supreme Court affirmed, holding that none of Appellant's arguments on appeal had merit and that the circuit court did not err in denying postconviction relief. View "Gentry v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying and dismissing Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentences were illegal.After a jury trial, Appellant was convicted of second-degree murder and sentenced as a habitual offender to eighty years' imprisonment. In his petition to correct an illegal sentence, Appellant asserted that the application of Ark. Code Ann. 5-4-501(c) to enhance his sentence was illegal and that the enhanced sentence violated the prohibition against the ex post facto application of criminal statutes. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his enhanced sentence was an illegal sentence pursuant to section 16-90-111. View "Rainer v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that it lacked jurisdiction to reduce Defendant's sentence, holding that there was no error.In 1993, Defendant pleaded guilty to first-degree murder and was sentenced to a term of life in prison. Defendant was nineteen years old when he committed the murder. At issue was Defendant's postconviction motion to reduce his sentence, in which Defendant argued that Arkansas courts should expand their interpretation of the Eighth Amendment as it relates to sentencing young adults. The Supreme Court affirmed the circuit court's denial of the motion, holding that the circuit court did not err in concluding that no Arkansas law gave it jurisdiction to modify Defendant's sentence under the circumstances of this case. View "Robinson v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's Rule 37 petition alleging ineffective assistance of counsel during his criminal trial, holding that there was no error or abuse of discretion.Defendant was convicted of and sentenced to death for capital murder. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief arguing that his trial counsel were constitutionally ineffective for multiple reasons. The circuit court denied the petition. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Holland v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law

The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder, kidnapping, aggravated robbery, and theft of property but remanded for the circuit court to correct the sentencing order, holding that there was no reversible error.Specifically, the Supreme Court held (1) the circuit court did not err in denying Appellant's motion for directed verdict on the capital-murder, kidnapping, and aggravated-robbery charges; (2) the circuit court did not abuse its discretion in denying Defendant's motion to suppress; (3) due to a discrepancy between the sentencing order and the pronouncement of sentence, this matter must be remanded for the court to correct the order; (4) the circuit court did not abuse its discretion in admitting three exhibits over Appellant's hearsay objections; (5) the circuit court did not abuse its discretion by allowing the State to question Appellant about three prior bad acts; and (6) Appellant was not entitled to relief on his remaining claims of error. View "Smith v. State" on Justia Law

The Supreme Court reversed the order of the circuit court enjoining the enforcement of the Bentonville School District's mask policy in favor of Plaintiffs, parents of school children, holding that the the circuit court abused its discretion in granting Plaintiffs' motion for a temporary restraining order (TRO).In granting the TRO, the circuit court concluded that the school policy at issue violated Plaintiffs' right under Ark. Const. art. II, 21 and 29 to care for their children and that the District lacked the authority to issue the mask policy. The Supreme Court reversed, holding that (1) the circuit court abused its discretion in finding that the policy violated Plaintiffs' constitutional rights and was enacted without proper authority; and (2) Plaintiffs failed to show that irreparable harm would result in the absence of a TRO. View "Bentonville School District v. Sitton" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the circuit court denying the State's motion to dismiss and granting a preliminary injunction in favor of Plaintiff, holding that the preliminary injunction was granted erroneously.Plaintiff, a hearing-instrument dispenser whose license was not renewed, brought this action against the Arkansas Department of Health, the Secretary of Health, and Arkansas Board of Hearing Instrument Dispensers, and the Executive Director of the Board of Hearing Instrument Dispensers (collectively, the State), arguing that the Board's refusal to provide him a proper renewal notice and a hearing violated his due process and equal protection rights and was an arbitrary and capricious abuse of the Board's power. The circuit court granted Plaintiff's request for a temporary injunction and declaratory relief. The Supreme Court reversed in part, holding (1) Plaintiff adequately pleaded a due process claim; (2) Plaintiff's equal protection claim was barred by sovereign immunity; and (3) because the preliminary injunction order contained no findings on irreparable harm or likelihood of success on the merits, the case must be remanded for findings in accordance with Ark. R. Civ. P. 65(d)(1). View "Arkansas Department of Health v. Solomon" on Justia Law