Justia Civil Rights Opinion Summaries

After a trial, Appellant was convicted of two counts of rape. Appellant subsequently filed a timely petition for postconviction relief. On the same day, Appellant filed a memorandum of law in support of the petition. In the petitions, Appellant presented three grounds for relief and additionally alleged he was entitled to an evidentiary hearing. The trial court treated the two pleadings as separate petitions and denied them without a hearing. Before the Supreme Court was Appellant's motion requesting an extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that the allegations in Appellant's petitions were without merit. View "Thompson v. State" on Justia Law

Petitioner entered a guilty plea to battery in the second degree and was sentenced to sixty months' imprisonment. Petitioner subsequently filed a timely pro se petition for postconviction relief, which the trial court denied. Petitioner failed to timely appeal but later sought leave to proceed with a belated appeal of the order, contending that the circuit court failed to send him a copy of the order denying his petition. The Supreme Court granted the motion, as nothing in the record suggested that Petitioner was properly notified that the order had been entered, and the State had not filed a response to Petitioner's motion to refute the allegations contained in it. View "Miller v. State" on Justia Law

After a jury trial, Appellant was convicted of residential burglary and rape and sentenced to an aggregate term of fifteen years' imprisonment. Appellant's motion seeking leave to proceed with a belated appeal was denied. Thereafter, Appellant unsuccessfully filed a pro se motion for a transcript of his trial at public expense. Defendant's appeal of the denial of that motion and his motion for reconsideration were both denied. Appellant then filed a second amended notice of appeal designating the order that denied the motion for transcript and the order that denied the motion for reconsideration. The Supreme Court dismissed the appeal and declared the motion related to that appeal moot, holding that Appellant failed to show the transcript should be provided to him at no cost, and therefore, the trial court did not err in its judgment. View "Koontz v. State" on Justia Law

Defendant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. The Supreme Court subsequently affirmed the circuit court's denial of Defendant's petition for writ of habeas corpus, concluding that Defendant's sentence did not violate the Eighth and Fourteenth Amendments even though Defendant was only fourteen years old at the time he committed the crimes. The U.S. Supreme Court remanded the case, holding that Arkansas's sentencing scheme violated the Eighth Amendment because it imposed a mandatory sentence of life without parole upon Defendant despite his having been under age eighteen at the time he committed capital murder. On remand, the Supreme Court reversed the denial of the petition for writ of habeas corpus and issued the writ. Remanded for resentencing. View "Jackson v. Norris" on Justia Law

Following a jury trial, Appellant was convicted of capital murder and sentenced to life in prison without parole. The Supreme Court affirmed the conviction and sentence. Appellant subsequently filed a timely pro se petition for postconviction relief, alleging that he had received ineffective assistance of counsel at trial. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's arguments that the trial court erred by not allowing him to subpoena a juror from his trial and by limiting his examination of a witness at the hearing were precluded from review; (2) the circuit court did not err by not permitting Appellant to amend his petition; (3) the circuit court did not prejudicially err by not invoking the rule to exclude Appellant's trial counsel from hearing the testimony of other witnesses; and (4) the circuit court did not err in denying Appellant's petition for postconviction relief. View "Adams v. State" on Justia Law

Defendant was arrested for several crimes, and the circuit court set Defendant's bail at $75,000. A bail-bond agent executed the bond and Defendant was released from jail. When the bail-bond company attempted to present Defendant's check for payment, it found the account had been closed. Defendant was subsequently charged with theft of services for his failure to pay the bail-bond company in violation of Ark. Code Ann. 5-36-104. The circuit court granted Defendant's motion for directed verdict, finding that the State had failed to present sufficient evidence that Defendant had violated section 5-36-104. The State appealed. The Supreme Court dismissed the appeal, holding that the State is not allowed to appeal from a directed verdict acquitting the defendant when the sole issue is the sufficiency of the evidence of the defendant's guilt. View "State v. Williams" on Justia Law

Petitioner, an inmate, filed a petition for postconviction relief. Petitioner was represented in the proceeding by his retained attorney (Attorney). No appeal was taken from the order, and Petitioner filed a pro se motion in the Supreme Court seeking to proceed with a belated appeal, contending that he instructed Attorney on the day the order denying postconviction relief was entered to perfect an appeal from the order. The Court remanded for an evidentiary hearing on the issue of whether Attorney was informed by Petitioner within the time period allowed for filing a notice of appeal that Petitioner desired to appeal from the order. The circuit court determined that Petitioner had sufficiently informed Attorney of his desire to appeal and that Attorney was obligated to file a notice of appeal. Accordingly, the Supreme Court granted Petitioner's pro se motion for belated appeal. View "Smith v. State" on Justia Law

After a jury trial, Appellant was convicted of sexual assault in the second degree. The Supreme Court reversed the conviction and remanded for a new trial, holding (1) the testimony of a witness regarding a prior inconsistent statement made by the victim should have been allowed into evidence as impeachment evidence, and because the victim's credibility was a major consideration for the jury, the error was not harmless; and (2) pursuant to Bing v. State, the circuit court erred by admitting hearsay evidence when it allowed the victim's father to testify as to what she had told him about the incident one month after it occurred. View "Scamardo v. State" on Justia Law

Appellant, an inmate, filed a petition for postconviction relief, which the trial court denied. Appellant appealed and filed two motions asserting that the record on appeal was incomplete, that the missing portions were necessary for preparation of his brief, and that, as a result of the omission, the proceedings to convict him were rendered void. The Supreme Court treated the two motions, in part, as motions to supplement the record. The Court then granted the motions in part, issuing a writ of certiorari for the circuit court clerk to provide a supplemental record containing the transcript and record of the plea-and-arraignment hearing that was referenced in the order denying postconviction relief. View "Rice v. State" on Justia Law

Appellant was convicted of residential burglary and attempted rape. The court of appeals affirmed the convictions and sentence. Appellant subsequently filed a petition for postconviction relief and a petition for writ of habeas corpus, asserting he was entitled to DNA testing of hair recovered from the crime scene in light of a newly available method of testing. The circuit court denied relief. Appellant appealed, arguing that the circuit court abused its discretion in denying his request to test the additional hairs found at the crime scene. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Appellant's request, as none of the evidence that might potentially result from the testing of the two additional hairs as sought by Appellant would raise a reasonable probability that Appellant did not commit the offense. View "Pankau v. State" on Justia Law