Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of burglary and attempted rape and sentenced as a habitual offender to an aggregate term of 600 months in prison. Several years later, Appellant filed in the Hot Spring County Circuit Court, the county in which Appellant was incarcerated, a petition for writ of habeas corpus. Appellant was subsequently transferred to a facility in a different county. The circuit court denied Appellant's petition. The Supreme Court dismissed Appellant's appeal, holding that, although the Hot Spring County Circuit Court may have retained subject-matter jurisdiction over Appellant, it did not retain personal jurisdiction over him because Appellant was no longer detained in the county. View "Turner v. State" on Justia Law

Appellee was charged with aggravated robbery, theft of property, and possession of firearms by certain persons. Appellee filed a motion to suppress the evidence obtained by Sherwood police officers on a home located outside the city limits of Sherwood on the grounds that they were not authorized to execute the arrest warrant and the search warrant. Following a hearing, the circuit court granted the motion, concluding that it was per se unreasonable for officers to execute an extraterritorial search warrant without the cooperation of local law enforcement. The Supreme Court reversed and remanded, holding that, under the totality of the circumstances and in view of the applicable statutory authority, court rules, and case law, the execution of the search warrant was not per se unreasonable such that it warranted suppression of the seized evidence. View "State v. Robinson" on Justia Law

Appellant entered a plea of nolo contendere to battery in the first degree and was sentenced as a habitual offender to 132 months' imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, contending that he was denied effective assistance of counsel and that the trial court erred in not advising him when the plea was entered that he would not be eligible for parole. After an evidentiary hearing, the trial court denied the petition. The Supreme Court affirmed, holding (1) the trial court did not err in finding that Appellant's trial counsel did not provide ineffective assistance; and (2) Appellant failed to demonstrate that his plea was not a valid plea. View "Paige v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and tampering with evidence and sentenced to life imprisonment without parole. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for a writ of habeas corpus, raising allegations of trial error, prosecutorial misconduct, and ineffective assistance of counsel. The petition also reiterated issues raised on direct appeal. The circuit court dismissed the petition. The Supreme Court dismissed Appellant's appeal and mooted the motions related the appeal, holding that because failed to raise a claim within the purview of a habeas action, Appellant failed to establish that a writ of habeas corpus should issue in her case. View "Meadows v. State" on Justia Law

Appellant filed a pro se petition for writ of habeas corpus in the Lincoln County Circuit Court while he was incarcerated at an Arkansas Department of Correction facility in Lincoln County. Appellant was subsequently transferred to a facility in Hot Spring County. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal for a lack of jurisdiction, holding that, although the Lincoln County Circuit Court may have retained subject-matter jurisdiction over Appellant, it did not retain personal jurisdiction over him where he had subsequently been transferred to a facility in a different county, and thus the court lacked the authority to issue and make a returnable writ. View "Jones v. Hobbs" on Justia Law

In 2003, Appellant pleaded guilty to first-degree murder and was sentenced to 480 months' imprisonment. In 2012, Appellant filed a pro se complaint for declaratory judgment and petition for writ of mandamus against the Arkansas Department of Correction (ADC) director and records supervisor, contending that he should not be required by Ark. Code Ann. 16-93-611 to serve seventy percent of his sentence before being eligible for parole or transfer because the statute was unconstitutional and conflicted with other state statutes. The circuit court denied the complaint and petition. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding that Appellant failed to state a basis for declaratory judgment, and without establishing a right to declaratory judgment, Appellant provided no basis for a writ of mandamus to issue. View "Gardner v. Hobbs" on Justia Law

In 1999, after a jury trial, Appellant was convicted of capital murder and rape and sentenced to death. Counsel was subsequently appointed to represent Appellant in postconviction proceedings. Counsel decided to forgo Ark. R. Crim. P. 37 relief. In 2006, Appellant filed a Rule 37 petition for postconviction relief, asserting allegations of ineffective assistance of trial counsel and that he was mentally retarded and therefore could not be executed. In 2012, the circuit court summarily dismissed the petition as untimely. The Supreme Court reversed, holding that, under the circumstances of this case and considering the punishment at issue, the circuit court erred in summarily dismissing Appellant's Rule 37 petition in the absence of a hearing and specific written findings on the issue of whether good cause existed for the belated filing of the petition. Remanded. View "Engram v. State" on Justia Law

In 2009, Appellant entered a plea of guilty to aggravated robbery and battery in the second degree. Appellant's probation for an earlier conviction for aggravated assault was also revoked. The circuit court imposed an aggregate sentence of 180 months' imprisonment. In 2013, Appellant filed a pro se petition to correct an illegal sentence, alleging that she was forced to sign a plea agreement by which she would be required to serve seventy percent of the sentence imposed and that, at the time, she believed she would be required to serve only fifty percent of the sentence. The trial court denied the petition. The Supreme Court dismissed Appellant's appeal, holding that the petition was not timely filed as to the judgment-and-commitment order or the revocation order, and thus the trial court lacked jurisdiction to grant the requested relief. View "Ybarra v. State" on Justia Law

In 1998, after a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to an aggregate term of sixty-five years' imprisonment. The court of appeals affirmed. In 2010, Appellant filed a petition for writ of habeas corpus under Act 1780 of 2001 seeking scientific testing of certain evidence. The circuit court denied the petition, finding it to be untimely because the evidence was not newly discovered for purposes of the Act. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's petition on the ground that it was untimely filed because Appellant failed to rebut the presumption against timeliness; and (2) the remainder of Appellant's petition raised claims that were not cognizable in a petition for habeas corpus, and therefore, the circuit court's denial of Appellant's petition was not clearly erroneous. View "Turner v. State" on Justia Law

In 2008, Appellant entered a negotiated plea of guilty in the Carroll County Circuit Court to first-degree stalking, kidnapping, residential burglary, and misdemeanor theft of property. In 2012, Appellant filed in the Carroll County Circuit Court a pro se petition for writ of habeas corpus. The circuit court denied the petition. Appellant appealed and filed a motion to appoint counsel. The Supreme Court dismissed the appeal and declared the motion moot, holding that because Appellant was not incarcerated at a facility within Carroll County when he filed his petition, the circuit court lacked personal jurisdiction to effect Appellant's relief from custody. View "Meraz v. State" on Justia Law