Justia Civil Rights Opinion Summaries

Appellant filed a pro se petition for writ of habeas corpus in the Jackson County Circuit Court, stating that she was incarcerated at a facility in Jackson County. Appellant was subsequently transferred to a facility in a different county. The Supreme Court dismissed the appeal, holding that because a circuit court does not have jurisdiction to release on a writ of habeas corpus a prisoner not in custody in that court's jurisdiction, the Jackson County Circuit Court lacked personal jurisdiction over Petitioner where she was no longer incarcerated in the county where her petition was filed. View "Zachry v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and of using a firearm during the commission of the felony. Appellant appealed, arguing that there was insufficient evidence to support his conviction and that the trial court erred in denying his motion to suppress his confession made to police. The Supreme Court affirmed, holding (1) The State offered substantial evidence of Appellant's intent to commit first-degree murder; and (2) the trial court did not err in denying Appellant's motion to suppress or in finding Appellant's waiver of his Miranda rights was voluntarily, knowingly, and intelligently made. View "Williamson v. State" on Justia Law

In 2003, the county prosecutor filed a delinquency petition against Appellee, who was sixteen years old at the time. Appellee later pled no contest to the charge of sexual assault in the second degree, and the circuit court entered an order adjudicating Appellee delinquent. After Appellee was released from the custody of youth services, the circuit court ordered Appellee to register as a moderate-risk sex offender. Two years later, Appellant unsuccessfully filed a petition requesting that his name be removed from the sex-offender registry. After Appellee had turned twenty-one, he filed a petition again requesting that he no longer be required to register as a sex offender or that his name appear on the registry. The State filed a motion to dismiss, arguing, inter alia, that the circuit court lacked jurisdiction to consider Appellee's petition because he was no longer a juvenile. The circuit court released Appellee of his requirement to register and removed his name from the sex-offender registry. The State appealed. The Supreme Court affirmed, holding that the State's arguments on appeal lacked merit. View "State v. V.H." on Justia Law

After a jury trial, Appellant was convicted of several drug-related sentences. The conviction was affirmed on appeal. Appellant subsequently filed a pro se petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding (1) the trial court did not err in not holding an evidentiary hearing on Appellant's petition; (2) the trial court did not err in failing to grant Appellant's petition based on his argument that trial counsel provided ineffective assistance by deciding not to call a certain witness; and (3) Appellant's third argument on appeal was without merit. View "Singleton v. State" on Justia Law

Appellant pleaded guilty to multiple felony offenses, including the Class Y felony offense of possession of methamphetamine with intent to deliver. The trial court later granted the State's petition to revoke the suspended imposition of sentence for the offenses on the ground that Appellant failed to comply with the conditions agreed upon when he entered the plea. Appellant appealed from the revocation order, and the court of appeals affirmed. Appellant later field a pro se petition for writ of habeas corpus alleging, as he had done on appeal from the revocation order, that the judgment-and-commitment order was invalid because the trial court had imposed a suspended sentence for the Class Y felony. The circuit court dismissed the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to raise again the issue concerning the suspended sentence; and (2) even if the allegation raised by Appellant had not already been settled, Appellant failed to establish that the writ should issue. View "Loftis v. Hobbs" on Justia Law

In 1995, Appellant was convicted of first-degree murder. In 2012, Appellant filed a motion "challenging statutory construction and interpretation" and seeking a "judgment of acquittal" on his conviction. The circuit court treated the motion as one for habeas relief and then dismissed the motion. The Supreme Court dismissed Appellant's appeal, holding (1) the circuit court appropriately treated Appellant's motion as one for habeas relief; (2) because Appellant was not incarcerated within that circuit court's jurisdiction, the court did not have jurisdiction to grant habeas relief; and (3) Appellant's claim of insufficient evidence failed to state grounds for habeas relief. View "Hill v. State" on Justia Law

In 1995, Appellant was convicted of first-degree murder. More than fifteen years after the judgment had been entered, Appellant filed a motion to vacate, set aside, and discharge his conviction seeking fingerprint testing of the gun used in the murder under Act 1780 of 2001 Acts of Arkansas. There are a number of predicate requirements that must be met before a court can order testing under the Act, including the requirement that petitioners who file a motion for testing more than thirty-six months after the entry of the judgment of conviction rebut a presumption against timeliness. The circuit court denied the motion. The Supreme Court affirmed, holding that the trial court lacked jurisdiction under Act 1780 to grant relief on Appellant's motion because Appellant failed to rebut the presumption against timeliness. View "Hill v. State" on Justia Law

In 1995, Appellant was convicted of capital murder and sentenced to life imprisonment in the Grant County circuit court. In 2012, Appellant filed in the Grant County circuit court a motion seeking a hearing on the denial of his request to the Arkansas State Crime Laboratory under the Arkansas Freedom of Information Act (FOIA). The request sought a copy of fingerprint-analysis test results on a piece of evidence from the trial. The circuit court denied the motion. The Supreme Court dismissed the appeal, holding that, under Ark. Code Ann. 25-19-107(a), the Grant County circuit court lacked jurisdiction to hear Appellant's motion. The Supreme Court affirmed because Appellant was not incarcerated in Grant County. View "Hill v. State" on Justia Law

In 1985, Appellant was convicted of aggravated robbery, and in 1986, Appellant was convicted of a separate robbery. In 2010, Appellant filed a pro se petition for writ of habeas corpus, contending in the circuit court that the trial court in his cases lacked subject-matter jurisdiction because the felony informations were filed in the trial court without a preliminary probable-cause hearing having been held beforehand in municipal court. The Supreme Court affirmed, holding that because Appellant's claims did not challenge the facial validity of the judgment or demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Halfacre v. Hobbs" on Justia Law

After a jury trial, Petitioner was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Petitioner later filed a second petition seeking to have jurisdiction reinvested in the circuit court to consider a petition for writ of error coram nobis. Petitioner raised the same claims of a Brady violation and of ineffective assistance of counsel that he raised in his first petition. The Supreme Court denied the petition, holding that Petitioner failed to present any basis to reinvest jurisdiction in the circuit court to consider his petition for a writ of error coram nobis. View "Burgie v. State" on Justia Law