Justia Civil Rights Opinion Summaries
Articles Posted in Arkansas Supreme Court
Laswell v. State
Appellant was convicted of capital murder and aggravated robbery. The Supreme Court affirmed. Eighty-three days after the mandate was issued, Appellant file a pro se request for postconviction relief, arguing that his counsel had provided ineffective assistance. The trial court dismissed the petition on the ground that it was untimely. Appellant appealed and filed a motion for reconsideration of the order dismissing the petition. Appellant also filed a motion for extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and mooted the motion, holding that because the petition before the trial court was not timely filed, the trial court had no jurisdiction to grant the requested relief.
View "Laswell v. State" on Justia Law
Hill v. State
After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed. After unsuccessfully pursuing various postconviction remedies, Appellant filed petitions that the circuit court treated as petitions for writ of habeas corpus. In the petitions, Appellant raised allegations of prosecutorial and police misconduct, ineffective assistance of counsel, due-process and equal-protection violations, and various trial errors. The circuit court denied the petitions on the ground that Appellant failed to allege the facial invalidity of the judgment-and-commitment order or that the court acted outside of its jurisdiction. The curt further found that Appellant failed to present evidence that he was being illegally detained. The Supreme Court affirmed, holding that Appellant stated no basis to support issuance of the writ. View "Hill v. State" on Justia Law
Harris v. State
Petitioner was convicted of two counts of aggravated robbery, two counts of theft of property, and employing a firearm while committing the crimes. Seventy-three days after the court of appeals issued its mandate affirming the convictions, Petitioner filed a pro se petition for postconviction relief, alleging that his counsel had rendered ineffective assistance and that the enhancement of his sentence was in error. The trial court denied the petition on the ground that it was untimely filed. Petitioner sought leave to proceed with a belated appeal. The Supreme Court denied the motion because Petitioner could not prevail if an appeal were permitted to go forward where the the petition before the trial court was not timely filed, and thus, the trial court had no jurisdiction to grant the relief sought. View "Harris v. State" on Justia Law
Gardner v. State
After a jury trial, Appellant was convicted of capital murder and aggravated robbery and sentenced as a habitual offender to an aggregate term of life imprisonment without parole. Appellant subsequently field a pro se petition for writ of habeas corpus, seeking scientific testing of a gun discovered inside the apartment shared by the victim and a witness to the murder and of shell casings found outside the apartment. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and mooted the motions related to the appeal, holding (1) because Appellant did not show the testing could satisfy Ark. Code Ann. 16-112-202, the circuit court did not err in denying relief; and (2) dismissal of the petition was proper because it was not timely filed. View "Gardner v. State" on Justia Law
Garcia v. State
After a jury trial, Appellant was convicted of two counts of rape and one count of sexual assault in the second degree. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial attorneys had rendered effective assistance. The trial court dismissed the petition. The Supreme Court affirmed the dismissal and mooted the motions related to Appellant's appeal, holding (1) the trial court did not err in finding that counsel did not provide ineffective assistance; and (2) the trial court did not err in failing to hold a hearing on Appellant's postconviction relief petition. View "Garcia v. State" on Justia Law
Bannister v. State
Petitioner filed a pro se petition for writ of error coram nobis in his criminal case, which was denied. Petitioner subsequently filed a motion for belated appeal in order to challenge the order denying his motion. Plaintiff, however, sought to appeal without a certified record or, in the alternative, sought an order directing the circuit clerk to provide the certified record necessary to file the motion for belated appeal. The Supreme Court denied the motion because Petitioner failed to meet his burden of providing a certified record with a motion for belated appeal sufficient to establish the Supreme Court's jurisdiction and sufficient to allow the Court to rule on the merits of his motion. View "Bannister v. State" on Justia Law
Allen v. State
After a jury trial, Appellant was convicted of capital murder, committing a terroristic act, and using a firearm during the commission of a felony. Appellant was sentenced to life imprisonment plus a term of ten years. Appellant appealed, arguing that the circuit court erred in excluding Ark. R. Evid. 404(b) testimony about the alleged bad acts by the State's primary eyewitness. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in excluding the evidence because Appellant failed to show that the testimony regarding the eyewitness's bad acts was relevant to any material issue in this case. View "Allen v. State" on Justia Law
Williams v. State
After a jury trial, Appellant was convicted of rape and sentenced to 720 months' imprisonment. Appellant subsequently filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, raising several grounds for relief. The trial court denied the petition. Appellant appealed, arguing that his counsel provided ineffective assistance. The Supreme Court affirmed, holding (1) because Appellant did not raise his ineffective assistance of counsel claim in the postconviction petition, the argument would not be addressed by the Court on appeal; and (2) to the extent Appellant argued that the evidence was insufficient to sustain the judgment, Rule 37.1 does not provide a means to attack the weight of the evidence to support the conviction. View "Williams v. State" on Justia Law
Tate v. State
After a jury trial, Appellant was convicted of murder in the first degree. The jury declared that Appellant's sentence of 480 months' imprisonment should be enhanced by an additional term of 180 months' imprisonment for use of a firearm in the commission of the felony. The sentences were to be served consecutively. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging, among other claims, that the trial court erred when it accepted the jury's recommendation and ordered the sentences to be served consecutively. The circuit court denied the petition. The Supreme Court affirmed, holding that because Appellant's claims did not demonstrate the facial invalidity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Tate v. State" on Justia Law
Strong v. Hobbs
After a jury trial, Appellant was convicted of two counts of rape and sentenced to two consecutive life sentences. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging a number of grounds for relief. The circuit court dismissed the petition without a hearing. Appellant appealed, stating that he was entitled to habeas relief based on, inter alia, violations of due process, prosecutorial misconduct, and ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the circuit court did not err by not conducting a hearing, as Appellant failed to demonstrate probable cause for the issuance of the writ; (2) the circuit court did not err by not making extensive written findings to support its decision; (3) several of Appellant's arguments on appeal were barred by the law-of-the-case doctrine; and (4) Appellant's reviewable claims were without merit. View "Strong v. Hobbs" on Justia Law