Justia Civil Rights Opinion Summaries

Appellants, state police officers, brought this suit individually and on behalf of a class consisting of members of the Arkansas State Police Retirement System (ASPRS), contending that various state defendants had violated the law by failing to properly fund the ASPRS between 1992 and 2003 and that the improper funding violated the Arkansas Constitution. The circuit court dismissed some of Appellants' claims and remanded. On remand, the circuit court granted summary judgment for Defendants. On appeal, Appellants asserted that the circuit court erred in finding that a uniform and travel-expense allowance provided for in Ark. Code Ann. 12-8-209 was not reportable to the ASPRS as a portion of payroll pursuant to Ark. Code Ann. 24-6-209(a). The Supreme Court affirmed, holding that section 24-6-209(a) does not include a uniform and travel-expense allowance such that it is reportable to ASPRS for purposes of calculating retirement benefits. View "McLemore v. Weiss" on Justia Law

Appellant was a police department officer when he arrested Appellee for disorderly conduct and refusal to submit to arrest. Appellee was convicted of both offenses. The circuit court subsequently overturned the disorderly-conduct conviction. Appellee brought suit against Appellant in his individual and official capacities in the U.S. district court. After Appellee's federal case was dismissed, she brought suit against Appellant in his individual and official capacities in state court. The suit was virtually identical to the suit brought in federal court. Appellant filed a motion for judgment on the pleadings, arguing that Appellee's cause of action was barred by collateral estoppel and that he was entitled to qualified immunity. The circuit court denied Appellant's motion, and Appellant brought this interlocutory appeal. The Supreme Court reversed and remanded, holding (1) Appellant was entitled to qualified immunity on Appellee's right-to-remonstrate claim; and (2) collateral estoppel barred the remaining claims. View "Graham v. Cawthorn" on Justia Law

After Appellant was charged with capital murder and kidnapping he entered a negotiated plea to first-degree murder. Appellant later filed a petition for writ of habeas corpus, alleging, inter alia, the trial court lacked jurisdiction, the filing of the information subjected him to prejudice and was a double-jeopardy violation, and the conviction was invalid. The circuit court denied the petition. The Supreme Court affirmed, holding that, to the extent Appellant's claims alleged that the trial court lacked jurisdiction or that the commitment was invalid on its fact, none demonstrated probable cause to support the basis alleged. View "Bryant v. May" on Justia Law

After a jury trial, Appellant was convicted of the rape of two sisters, who were minors at the time of the offenses. The court of appeals affirmed. Appellant subsequently timely filed a pro se petition for postconviction relief, contending (1) he was entitled to a new trial because there were a number of errors in his trial, and (2) his trial counsel was ineffective. The trial court denied the petition. The Supreme Court dismissed Appellant's petition and declared Appellant's motion to file a belated brief moot, holding (1) Appellant's first allegation of error was not cognizable in a petition for postconviction relief; and (2) Appellant failed to provide facts that affirmatively supported his claim that counsel's conduct prejudiced him under the standards set forth in Strickland v. Washington. View "Webb v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder in the death of Odilon Guerrero during an aggravated robbery. Defendant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting that his trial counsel was ineffective for incorrectly identifying letters used to impeach a witness for the State and for failing to call two witnesses. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant was not prejudiced by his attorney's cross examination of the State's witness; and (2) Appellant did not show he was prejudiced by his trial counsel's failure to call the two witnesses. View "Taylor v. State" on Justia Law

Appellant pled guilty to one count of delivery of a controlled substance. The trial court revoked Appellant's probation and imposed a sentence of 132 months' incarceration. Appellant subsequently filed a petition for writ of habeas corpus, alleging multiple grounds for the writ, including the claim that the sentence was illegal in that it imposed a sentence that required Appellant's participation in a drug-treatment program. The circuit court denied the petition. The Supreme Court reversed and remanded with directions to strike an unlawful condition in the judgment, holding that the circuit court imposed an illegal sentence when it attempted to require Appellant to undergo drug treatment as a condition of incarceration. View "Murphy v. State" on Justia Law

Appellant pled guilty to false imprisonment, theft of property, and domestic battery committed in the presence of a child. Appellant was sentenced as a habitual offender to an aggregate term of 1560 months' imprisonment. In 2010, the trial court amended the 2005 judgment-and-commitment order to reflect that Appellant was a sex or child offender and was ordered to register as a sex offender. Appellant subsequently filed a petition for postconviction relief, contending that the amended judgment was void and illegal. The Supreme Court dismissed the appeal. In 2012, Appellant filed a pro se petition for writ of habeas corpus, contending (1) the trial court did not have jurisdiction to amend the judgment-and-commitment order in 2010 because the sentence had already been put into execution, and (2) one of the charges of false imprisonment of which he was convicted was not applicable to him because he was the parent of the child involved. The circuit court dismissed the petition, concluding that Appellant failed to state a claim sufficient to warrant issuance of a writ of habeas corpus. Finding no error, the Supreme Court affirmed. View "Justus v. Hobbs" on Justia Law

In Hobbs v. Jones, Petitioners challenged Arkansas's method-of-execution statute (the statute). Prior to submission, Petitioners filed renewed motions for stays of execution during the pendency of their appeal, which the Supreme Court granted. In Hobbs, the Court held that the statute violated the Arkansas Constitution's separation-of-powers doctrine. The mandate issued on July 11, 2012. The General Assembly subsequently enacted Act 139 or 2013, which amended the statute. On March 8, 2013, the Arkansas Department of Correction and its director (collectively, Respondents) filed a motion to lift the stays of execution. On March 18, 2013, Petitioners opposed lifting the stays and filed a motion to take the matter as a case, claiming that the Court must now determine whether Act 139 passed constitutional muster. The Supreme Court (1) declared moot Respondents' motion to lift the stays of execution, as the stays of execution dissolved upon the issuance of the Court's mandate on July 11, 2012; and (2) denied Petitioners' request to take the matter as a case, as the Court did not have original jurisdiction of the matter. View "Jones v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated robbery, one count of possession of firearms by a felon, and two counts of misdemeanor theft. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging that his trial counsel was ineffective. After a hearing, the circuit court denied the petition on the basis that Appellant had failed to establish that trial counsel's representation fell below the standards set in Strickland v. Washington. The Supreme Court affirmed, holding that the circuit court's finding of a failure to demonstrate Strickland prejudice was not clearly erroneous. View "Golden v. State" on Justia Law

Appellant was found guilty of the rape of a seven-year-old child and was sentenced as a habitual offender to a term of life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001 seeking DNA testing and a voice stress test to be performed on the victim. Thereafter, Appellant successfully filed a motion to dismiss the habeas petition. Approximately two weeks later, Appellant filed a notice of appeal. The Supreme Court dismissed the appeal, holding that there was no ground for an appeal. View "Fields v. State" on Justia Law