Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment. More than two decades later, Appellant filed a pro se petition for writ of habeas corpus in the circuit court, alleging error in his trial. The circuit court dismissed the petition. On appeal, Appellant contended that an automatic sentence of life without parole is illegal on its face and a violation of the state and federal constitutional prohibition of ex post facto laws. The Supreme Court affirmed, holding that because Appellant's claims did not challenge the facial validity 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 "Jones v. Hobbs" on Justia Law

In 1984, Appellant was charged in drew County with rape. The trial was held in Ashley County. A jury found Appellant guilty, and the judgment-and-commitment order was entered in Drew County. Appellant challenged the sentencing court's jurisdiction on appeal. The Supreme Court affirmed with the modification that the judgment-and-commitment order be filed in Ashley County. In 1984, Appellant also pled guilty to three additional felony offenses, and in 2007, Appellant pled guilty to eight more felony offenses. In 2011, Appellant filed a petition for writ of habeas corpus, which the circuit court dismissed. The Supreme Court affirmed, holding (1) Appellant's contention that the change of venue from Drew to Ashley county rendered the judgment in that case void was barred by res judicata; and (2) the remainder of Appellant's claims were not grounds for habeas relief. View "Douglas v. Hobbs" on Justia Law

Appellant pled guilty to two counts of rape in the Garland County Circuit Court. Appellant subsequently filed a pro se petition for writ of habeas corpus in the trial court in Garland County. At the time the petition was filed, Appellant was incarcerated at the Arkansas Department of Correction located in Hot Spring County. The trial court denied the petition. Appellant appealed and filed a motion to file a belated brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the Garland County Circuit Court did not have personal jurisdiction to issue a writ of habeas corpus where Appellant was not in custody within the court's jurisdiction. View "Cooper v. Hobbs" on Justia Law

After a jury trial, Defendant was convicted of five counts of committing a terroristic act and one count of possession of a firearm by a felon. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging, among other things, that his counsel was ineffective. The trial court denied the petition. The Supreme Court affirmed, holding that counsel did not provide ineffective assistance for (1) deciding not to challenge the information; (2) not challenging the jury instructions or verdict forms that tracked the elements of the charged crimes; and (3) failing to make a sufficient motion for a directed verdict to preserve a sufficiency-of-evidence argument for appeal. View "Anderson v. State" on Justia Law

After a bench trial, Defendant was convicted of rape. Defendant subsequently filed a petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel. The circuit court denied the petition. Defendant appealed and filed motions for an extension of time to file his brief-in-chief and for a copy of the record on appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that Defendant failed to provide facts affirmatively supporting the claims that his counsel's conduct prejudiced him under the standards set out in Strickland v. Washington. View "Stevenson v. State" on Justia Law

In 1994, Defendant pled guilty to attempted rape and to violation of a minor. Defendant committed the offenses in 1992 or 1993. Defendant was sentenced to concurrent terms of twenty years' imprisonment for the attempted rape charge. In 2010, Defendant filed a pro se petition to correct an illegal sentence, arguing that his twenty-year sentence amounted to an ex-post-facto violation because the court applied the transfer-eligibility statute, which became effective in 1994, to his sentence. Specifically, Defendant alleged that the parole-eligibility statute in effect at the time of the commission of the crime should be applied to his sentence. The circuit court denied Defendant's petition. The Supreme Court affirmed, holding that because Appellant's petition was untimely, the circuit court did not err in denying the petition. View "Hodges v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple drug-related offenses. The court of appeals affirmed. Defendant subsequently filed a petition for postconviction relief, alleging that his trial counsel was ineffective for failing to impeach one of the state's witnesses, failing to object to comments made by the State in closing arguments, and failing to challenge the jury-selection process, among other reasons. The circuit court denied Appellant's petition without a hearing. The Supreme Court affirmed the denial of postconviction relief on all points, holding that the circuit court did not commit prejudicial error in denying postconviction relief. View "Bond v. State" on Justia Law

After a jury trial, Petitioner was convicted of rape and sentenced as a habitual offender to life imprisonment. Petitioner subsequently filed a pro se petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis. After the petition was denied, Petitioner filed another pro se petition seeking leave to have jurisdiction reinvested in the trial court to consider a coram-nobis petition. The Supreme Court dismissed the petition, holding that Petitioner's successive application for coram-nobis relief was an abuse of the writ in that Petitioner alleged no facts sufficient to distinguish his claim in the instant petition from the claim in the first. View "Rodgers v. State" on Justia Law

Defendant was fined in the district court for driving sixteen miles over the speed limit. On appeal, Defendant was convicted of speeding in excess of fifteen miles per hour over the speed limit. The court of appeals reversed and dismissed Defendant's conviction. Defendant subsequently filed a motion for award of costs on appeal under Ark. R. Sup. Ct. 6-7. The Supreme Court accepted certification from the court of appeals to determine whether the State may be liable for costs under Rule 6-7. The Supreme Court denied the motion for costs on appeal, holding that Defendant's claim against the State was barred by the doctrine of sovereign immunity. View "Kiesling-Daugherty v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was not afforded effective assistance of counsel at trial. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant's allegation that his trial counsel was ineffective for failing to call a witness during the penalty phase of his trial was conclusory and thus without merit; and (2) the trial court did not err in finding Defendant's claim that his attorney should have secured a change of venue was conclusory in nature and not supported by facts. View "James v. State" on Justia Law