Justia Civil Rights Opinion Summaries

Appellant pleaded guilty to sexual assault in the first degree and was sentenced to 660 months' imprisonment. Appellant later filed a two pro se petitions to correct a sentence illegal on its face and to reduce sentence, arguing that his sentence was illegal because he was not proven to be a habitual offender with four or more prior felony convictions who was subject to an enhanced sentence. The trial court denied both petitions. The Supreme Court affirmed, holding that the trial court's decision to deny Appellant's petitions was not clearly erroneous because the sentence Appellant received was within the statutory range for the offense. View "Grissom v. State" on Justia Law

Appellant pleaded guilty to one count of rape in the Perry County Circuit Court and one count of rape in the Conway County Circuit Court and was sentenced to a term of imprisonment. Appellant subsequently filed a petition for a writ of habeas corpus in Hot Spring County, where he was incarcerated, arguing that the Perry County Circuit Court lacked jurisdiction to convict and sentence him because the information pertaining to the investigation of the crime to which he pled guilty in Perry County indicated that the alleged sexual activity took place in Conway County. The circuit court denied the habeas petition. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Appellant failed to demonstrate probable cause that the Perry County Circuit Court lacked territorial jurisdiction to convict and sentence him on the rape charge; and (2) Appellant's claim that the Conway County judgment-and-commitment order was invalid on its face was not cognizable in this habeas corpus proceeding. View "Fields v. Hobbs" on Justia Law

Appellant was convicted of multiple counts of unlawful charge of a firearm from a vehicle and was sentenced to a term of imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001 (Act), alleging claims of (1) actual innocence; (2) failure of proof because a gun was not recovered; and (3) ineffective assistance of counsel, insufficient evidence, and due process violations. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that the claims raised by Appellant were not cognizable under the Act, and therefore, the trial court correctly determined that the relief Appellant sought fell outside the statute's scope. View "Clemmons v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder in furtherance of aggravated robbery and sentenced to a term of life imprisonment. The Supreme Court affirmed the judgment of the circuit court, holding (1) there was substantial evidence to support the jury's verdict; and (2) Appellant failed to establish that the circuit court erred when it refused to instruct the jury with a disputed-accomplice liability instruction, as, even if the circuit court's failure to instruct the jury on the disputed-accomplice liability was error, Appellant failed to demonstrate that he was prejudiced by the circuit court's failure to give the instruction. View "Wells v. State" on Justia Law

While an inmate in the Arkansas Department of Correction (ADC) East Arkansas Regional Unit (EARU), Appellant stabbed a correctional officer in the chest with a piece of fence wire. Consequently, Appellant was transferred to the Varner Supermax Unit (VSM) of the ADC and assigned to the VSM Incentive Level Program. Appellant subsequently filed a complaint pursuant to the Arkansas Civil Rights Act, alleging that his placement in the VSM Incentive Level Program violated his constitutional rights, including his rights to due process and equal protection. The trial court dismissed the complaint. The Supreme Court affirmed, holding that because Appellant failed to raise any legitimate constitutional issue in his petition, the trial court did not err in dismissing the complaint based on Petitioner's failure to state a claim for relief. View "Waller v. Banks" on Justia Law

After a jury trial, Petitioner was convicted of possession of a controlled substance with intent to deliver, possession of drug paraphernalia, and simultaneous possession of drugs and firearms. Petitioner did not appeal but later sought leave to proceed with a belated appeal, contending that his retained attorney knew of his desire to appeal from the judgment but failed to file a notice of appeal. The Supreme Court denied Petitioner's motion, as (1) counsel was allowed to withdraw as Petitioner's attorney before the judgment of conviction was entered of record, and therefore, he was not responsible for perfecting an appeal; and (2) Petitioner failed to show good cause for his failure to comply with proper procedure. View "Steele v. State" on Justia Law

Appellant entered a plea of guilty to attempted capital murder, aggravated robbery, and three counts of aggravated assault. Appellant was sentenced to serve an aggregate sentence of 660 months' imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus, contending that the sentence imposed was illegal, rendering the judgment-and-commitment order invalid on its face. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition where (1) the sentence was not excessive, and the judgment-and-commitment order was not invalid on its face; and (2) the remaining issues raised by Appellant were not cognizable in a writ of habeas corpus. View "Smith v. Hobbs" on Justia Law

In 1995, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed. In 2011, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001 seeking DNA and fingerprint testing of a rubber mask found at the crime scene. The trial court denied the petition. Appellant filed an appeal and moved for extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and mooted the motion, holding that because Appellant failed to rebut the presumption against timeliness or to satisfy the requirement that the proposed testing produced new material evidence that would both support the theory of defense presented at trial and raise a reasonable probability that the petitioner did not commit the offense, the trial court was not clearly erroneous in denying Appellant's petition for relief. View "Slocum v. State" on Justia Law

In 1983, Petitioner was convicted of capital murder and sentenced to life imprisonment without parole. In 2004, Petitioner filed a pro se petition for writ of habeas corpus pursuant to act 1780 or 2001 in which he requested DNA testing of blood samples he claimed had been collected from the crime scene. The trial court denied the petition, and the Supreme Court affirmed. In 2012, Petitioner filed another pro se petition for writ of habeas corpus seeking the use of the Automated Fingerprint Identification System to compare prints lifted from the crime scene to the prints of three individuals he argued may have committed the crime for which he was convicted. The trial court denied the petition on the basis that Petitioner could have included the claim in the petition filed in 2004. Petitioner subsequently filed a motion for reconsideration, which the trial court denied. Petitioner filed a motion for belated appeal, which the Supreme Court denied, holding that the habeas petition and motion for reconsideration were wholly without merit, and therefore, Appellant could not prevail on appeal. View "Penn v. State" on Justia Law

In 2005, Petitioners were convicted of various drug-related offenses. Petitioners subsequently filed a pro se joint petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis, arguing that the trial court denied them of their right to allocution before the entry of their judgments, that their counsel rendered ineffective assistance, and that they were deprived of the right to a speedy trial. The Supreme Court denied the petition, as all of Petitioners' claims were not subject to review in a coram-nobis proceeding. View "Myers v. State" on Justia Law