Justia Civil Rights Opinion Summaries
Articles Posted in Arkansas Supreme Court
Burgie v. Hobbs
Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order was invalid on its face and that the circuit court lacked jurisdiction. The circuit court denied the petition. Appellant appealed and filed several motions and a petition for writ of mandamus related to the appeal. The Supreme Court dismissed the appeal and declared the motions and petition for writ of mandamus moot, holding that Appellant did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue because his claims did not challenge the facial validity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction. View "Burgie v. Hobbs" on Justia Law
Anderson v. Hobbs
Appellant pleaded guilty to rape. Consequently, the trial court revoked Appellant's probationary sentences for three counts of first-degree carnal abuse. Appellant was sentenced accordingly. The Arkansas Department of Correction (ADC) calculated that after serving seventy percent of his thirty-year sentence for the rape conviction, Appellant would be eligible for transfer. Appellant filed a pro se motion for declaratory judgment, contending that the ADC erred in its calculation of his transfer-eligibility date. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to show how the ADC miscalculated his transfer-eligiblity date in a manner inconsistent with the law in effect at the time he committed the rape. View "Anderson v. Hobbs" on Justia Law
Akbar v. Hobbs
Appellant was convicted of first-degree murder and aggravated assault and sentenced to an aggregate term of life imprisonment. Petitioner subsequently filed a pro se petition for writ of habeas corpus, alleging that the trial court lacked jurisdiction to sentence him because the amended felony information charging him incorrectly changed the nature and degree of one of the charged crimes. The circuit court denied the order. The Supreme Court affirmed, holding that because Appellant did not establish a basis for holding that the judgment was invalid on its face or that the trial court was without jurisdiction, Appellant's allegation of error was not cognizable in a proceeding for the writ. View "Akbar v. Hobbs" on Justia Law
State v. Miller
In 1991, Appellee pled guilty to first-degree sexual abuse and second-degree false imprisonment. After Appellee was paroled in 1995, he was required to register as a sex offender. In 2012, Appellee sought an order terminating his obligation to register as a sex offender. After a hearing, the circuit court entered an order finding that Appellee was no longer required to register as a sex offender. The State appealed. The Supreme Court affirmed, holding that the circuit court did not clearly err in finding that Appellee was not likely to pose a threat to the safety of others and in therefore finding Appellee was ready to have the obligation to register lifted. View "State v. Miller" on Justia Law
Nelson v. Norris
After a jury trial, Appellant was convicted of possession of drug paraphernalia with intent to manufacture methamphetamine and possession of pseudoephedrine. Appellant subsequently filed a pro se petition for writ of habeas corpus. Appellant subsequently filed a second pro se petition for writ of habeas corpus, which the circuit court dismissed. Appellant appealed, contending that his sentence was illegal because the trial court erred in admitting evidence of his prior felony convictions and in allowing introduction of evidence seized in violation of the Fourth Amendment. The Supreme Court affirmed where Appellant failed to show the judgment of conviction was invalid on its face or that the trial court lacked jurisdiction. View "Nelson v. Norris" on Justia Law
Munnerlyn v. State
After a trial, Petitioner was convicted of three felony offenses and sentenced to life imprisonment. Petitioner subsequently filed a petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court denied relief, holding (1) Petitioner's argument that the arrest warrant was invalid was not cognizable under Rule 37.1; (2) Petitioner's argument that the felony information was invalid was not a jurisdictional matter and was not sufficient to void the judgment; (3) Petitioner's argument that he was not adequately informed of his Miranda rights when he confessed was waived; and (4) Petitioner's allegations of ineffective assistance were not grounds for relief. View "Munnerlyn v. State" on Justia Law
Morgan v. State
Appellant pled guilty to rape and first-degree sexual assault in 2003. In 2007 and 2011, Appellant filed three pro se petitions for writs of error coram nobis. In 2012, the circuit court denied the petitions in a single order. The Supreme Court dismissed Appellant's appeal and declared Appellant's petition for writ of certiorari to complete the appellate record moot, holding (1) because the 2007 petition was not included in the record, Appellant could not prevail as to those claims; (2) all claims in the 2011 petitions failed to allege a claim that would support error-coram-nobis relief; and (3) therefore, the trial court did not err in denying relief.
View "Morgan v. State" on Justia Law
McVane v. Hobbs
Appellant pled guilty to aggravated robbery in 2009. In 2011, Appellant filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order was invalid because the trial court failed to comply with the Arkansas Rules of Criminal Procedure. The trial court denied the writ. Specifically, Appellant asserted that the trial court violated certain court rules with regard to the acceptance of guilty pleas at his plea hearing. The Supreme Court affirmed, holding that because Appellant failed to show that the judgment of conviction was facially invalid or that the circuit court lacked jurisdiction, the trial court properly declined to issue a writ of habeas corpus. View "McVane v. Hobbs" on Justia Law
Malone v. Hobbs
After a jury trial, Appellant was found guilty of aggravated robbery, aggravated assault, and theft of property and was sentenced to an aggregate term of 348 years' imprisonment. The Supreme Court affirmed. Appellant subsequently field a pro se petition for writ of habeas corpus, asserting that proper procedure was not followed when he was extradited to Arkansas after his arrest in Tennessee, and a sentence in excess of 300 years was outside the statutory range for the offenses of which he was convicted. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant failed to state a claim sufficient to warrant issuance of a writ of habeas corpus, and therefore, the circuit court did not err in declining to issue the writ. View "Malone v. Hobbs" on Justia Law
Lewis v. State
After a trial, Appellant was convicted of murder in the first degree and battery in the third degree. Appellant's conviction was affirmed on appeal. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging that his due process rights were violated based on the constructive denial of counsel, judicial abuse of discretion, and prosecutorial misconduct. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because Appellant failed to show either that the judgment of conviction was invalid on its face or that the trial court lacked jurisdiction, the circuit court properly determined that the writ should not issue. View "Lewis v. State" on Justia Law