Justia Civil Rights Opinion Summaries
Articles Posted in Arkansas Supreme Court
Gardner v. Payne
The Supreme Court affirmed the order of the circuit court dismissing Appellant's petition for writ of habeas corpus, holding that there was no error.After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. The court sentenced Appellant as a habitual offender to an aggregate term of life imprisonment without parole. In his habeas corpus petition, Appellant claimed, among other things, that his convictions and sentences were invalid because the prosecutor did not sign the criminal information. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claims for habeas relief. View "Gardner v. Payne" on Justia Law
Gay v. State
The Supreme Court affirmed the supplemental order of the circuit court denying Ark. R. Crim. P. 37 relief, holding that the circuit court did not err.Defendant was convicted of capital murder and sentenced to death. Defendant later sought postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding (1) Defendant was not denied the right to a fair and impartial jury; (2) the circuit court did not clearly err in denying Defendant's ineffective assistance of counsel arguments; (3) Defendant's challenges to the third death-penalty verdict form did not constitute grounds for relief under Rule 37; (4) Defendant's challenges to the verdict forms did not constitute grounds for relief; and (5) Defendant's remaining allegations of error were without merit. View "Gay v. State" on Justia Law
Halliburton v. State
The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court did not err in denying relief.In denying and dismissing Appellant's petition, the circuit court found that the criminal information in this case was not deficient and that Appellant's counsel provided effective assistance. The Supreme Court affirmed, holding that, contrary to Appellant's contention on appeal, the criminal information complied with Ark. Const. art. VII, 49. View "Halliburton v. State" on Justia Law
Thomas v. State
The Supreme Court affirmed the trial court's judgment denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant's claims lacked merit.Appellant was convicted of capital murder and sentenced as a habitual offender to life imprisonment without parole. In his postconviction petition, Appellant argued, among other things, that his counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his allegations of error. View "Thomas v. State" on Justia Law
Medicanna, LLC v. Arkansas Department of Finance & Administration
The Supreme Court dismissed the circuit court's dismissal of Plaintiff's lawsuit against the Arkansas Department of Finance and Administration, Arkansas Alcoholic Beverage Control Division, Arkansas Medical Marijuana Commission (collectively, State Defendants) and Nature's Herbs and Wellness of Arkansas, LLC, holding that the Court lacked jurisdiction.Plaintiff brought this suit alleging violations of the Arkansas Medical Marijuana Commission's administrative rules, the Administrative Procedure Act, and Plaintiff's equal protection and due process rights. The circuit court concluded that Plaintiff lacked standing to bring its lawsuit and dismissed the complaint. The Supreme Court dismissed Plaintiff's appeal, holding that because the record was not filed within ninety days from the filing of the first notice of appeal this Court lacked jurisdiction over the appeal. View "Medicanna, LLC v. Arkansas Department of Finance & Administration" on Justia Law
Coakley v. State
The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief without holding an evidentiary hearing, holding that there was no error.Petitioner was convicted of first-degree murder and sentenced to life imprisonment without parole. In his petition for postconviction relief, Petitioner alleged that his counsel was ineffective for failing to develop the defense of provocation, among other things. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court's finding that Petitioner did not receive ineffective assistance of counsel was not clearly erroneous. View "Coakley v. State" on Justia Law
Chunestudy v. State
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise allegations that warranted coram nobis relief.Petitioner was found guilty of the rape of his minor daughter and sentenced to life imprisonment. In his petition for coram nobis relief, Petitioner argued that his daughter had recanted her trial testimony, his daughter perjured herself, and his trial counsel was ineffective. The Supreme Court denied the petition, holding that Petitioner failed to establish that he was entitled to the writ. View "Chunestudy v. State" on Justia Law
Arkansas Department of Finance & Administration v. Lewis
The Supreme Court reversed the ruling of the circuit court denying the State's motion to dismiss this complaint alleging that Defendants, in their official capacities, had terminated him in violation of public policy without a name-clearing hearing, holding that sovereign immunity barred Plaintiff's claims.After Plaintiff was involuntarily terminated from his employment he filed suit for wrongful termination and alleged a violation of his right to due process for failure to provide a name-clearing hearing. Appellants moved to dismiss the complaint on grounds of sovereign immunity. The motion was denied. The Supreme Court reversed, holding that Plaintiff failed to plead sufficient facts that asserted an exception to the sovereign-immunity doctrine. View "Arkansas Department of Finance & Administration v. Lewis" on Justia Law
Posted in:
Arkansas Supreme Court, Civil Rights
Jenkins v. Mercy Hospital Rogers
The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Plaintiff's employment discrimination complaint against Mercy Hospital Rogers, holding that the circuit court erred in dismissing Plaintiff's claim under the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108.Specifically, the Supreme Court held (1) Plaintiff failed to plead that Mercy made any false representations of material fact sufficient to sustain a fraud action; (2) because Plaintiff failed to state an exception to the at-will doctrine, the circuit court properly dismissed Plaintiff's wrongful termination claim; and (3) given the circuit court's lack of factual development on the issue, the Supreme Court cannot determine whether Mercy is a religious organization entitled to the ACRA religious-organization exemption, and therefore, remand was required. View "Jenkins v. Mercy Hospital Rogers" on Justia Law
Arkansas Department of Human Services Crimes Against Children Division v. Mitchell
The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law