Justia Civil Rights Opinion Summaries

Articles Posted in Arkansas Supreme Court
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In 2008, after a jury trial, Appellant was convicted of aggravated robbery, three counts of kidnapping, attempted capital murder, theft of property, aggravated assault, felony fleeing, and misdemeanor fleeing. The court of appeals affirmed. Appellant subsequently filed a timely petition for postconviction relief. The postconviction court denied the petition. The Supreme Court dismissed the appeal and declared Appellant's petition for writ of certiorari to complete the record moot, holding that because Appellant's petition was not in compliance with Ark. R. Crim. P. 37.1(c), which requires the petition be accompanied by a correctly verified affidavit, it should not have been accepted for filing, and it did not act to confer jurisdiction on the trial court to consider the merits of the petition. View "Page v. State" on Justia Law

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In 1998, Appellant was convicted of first-degree murder and sentenced to 720 months' imprisonment. The Supreme Court affirmed. In 2011, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, contending that DNA and fingerprint testing should be performed on a rubber mask that was introduced into evidence at his trial. The trial court denied the petition on the basis that it was not timely filed. Appellant lodged an appeal and sought to supplement the record on appeal. The Supreme Court denied the motion and dismissed the appeal, holding that Appellant failed to rebut the presumption against timeliness because the testing suggested by Appellant was either available at the time of his trial or not shown to be substantially more probative than technology available at that time. View "King v. State" on Justia Law

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After a jury trial, Defendant was convicted of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err by failing to grant a directed verdict, as the State introduced substantial evidence that Defendant acted with the purpose to kill the victim; and (2) the circuit court did not err in denying Defendant's motion for a directed verdict of acquittal on his affirmative defense of mental disease or defect, as the issue of Defendant's mental state was properly submitted to the jury and Defendant failed to prove that affirmative defense by a preponderance of the evidence. View "Kaufman v. State" on Justia Law

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After a jury trial, Appellant was found guilty of capital murder and sentenced to life without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, contending that he was not afforded effective assistance of counsel. The trial court denied the petition. Appellant appealed and sought by pro se motion an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that it was clear from the record that Appellant could not prevail on appeal if the appeal were permitted to go forward. View "Wedgeworth v. State" on Justia Law

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Petitioner was charged with capital murder and permitting the abuse of a minor by felony information on March 20, 2012. Petitioner pled not guilty to the charges, and the court set the case for jury trial on October 22, 2012. Citing trouble obtaining military records for mitigation purposes, Petitioner filed a motion for continuance. The court denied the motion without prejudice. On September 27, 2012, Petitioner filed a renewal of his motion for continuance, citing various objections. After a hearing, the court found that Defendant had failed to make the requisite factual showing and denied the motion. Thereafter, Petitioner filed a petition for writ of certiorari, maintaining that because of the special circumstances of this case - a complex death penalty case slated for trial merely six months after Petitioner was afforded the benefit of counsel - the Court should grant relief. The Supreme Court denied the writ because Petitioner had another adequate remedy at law - an appeal. View "Pedraza v. Circuit Court" on Justia Law

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Defendant was convicted and sentenced in the underlying criminal case. Defendant subsequently filed a pro se motion seeking leave to file a pro se petition for rehearing, challenging the admissibility of certain evidence and the sufficiency of the evidence to sustain the judgment, and arguing that his trial counsel provided ineffective assistance. The Supreme Court denied the motion, as Petitioner was represented by counsel on appeal who did not elect to file a petition for rehearing, and Petitioner's claim of ineffective assistance of counsel was not properly raised in a belated petition for rehearing. View "Fields v. State" on Justia Law

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Appellant was convicted of several counts of breaking or entering and theft of property and sentenced to 480 months' incarceration. After the judgment was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, raising a number of claims, including ineffective assistance of counsel and due-process violations. The trial court denied the petition, finding that Appellant had failed to present proof to support each of his claims. Appellant appealed and then filed a motion for an extension of time in which to file his brief and five other motions, all of which indicated an intention to supplement the record. The Supreme Court (1) granted in part, denied in part, and declared moot in part Appellant's motions to supplement; (2) declared moot Appellant's motion for extension of time; and (3) dismissed the appeal, holding that the trial court's findings in its order denying postconviction relief were not clearly erroneous, and Appellant could not prevail on appeal. View "Davis v. State" on Justia Law

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Appellant filed in the circuit court a pro se petition for postconviction relief. Appellant indicated in the heading to the petition that the petition encompassed six cases, and Appellant further indicated that he had entered pleas of guilty to felony offenses in the six cases. The trial court denied the petition. Appellant lodged an appeal and filed a motion for an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the record on appeal was clearly deficient because it contained only one judgment, and therefore, the record was not sufficient to determine if the issues for reversal were well founded or if the petition was timely filed as to every judgment. View "Townsend v. State" on Justia Law

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After a jury trial, Defendant was convicted of the first-degree murder of Michael Fox, who suffered three stab wounds. Defendant was sentenced to life in prison. The Supreme Court affirmed the conviction and sentence, holding that the circuit court (1) did not err in denying Defendant's directed-verdict motion, as substantial evidence supported the verdict; (2) did not err in denying Defendant's motion to suppress his statement to a police officer; (3) did not abuse its discretion in denying Defendant's motion for mistrial; (4) did not abuse its discretion in denying Defendant's motions to exclude prior bad acts involving Defendant's use of a knife; and (5) did not abuse its discretion in failing to exclude a plaster cast of the knife impression found in a seized knife box. View "Stevenson v. State" on Justia Law

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Petitioner filed a pro se petition for writ of habeas corpus in the circuit court where he was incarcerated. The circuit court dismissed the petition on May 31, 2012, and Petitioner sought reconsideration. The motion for reconsideration was denied on July 31, 2012. Petitioner did not file a notice of appeal from either order and sought leave in this motion to proceed with a belated appeal. The Supreme Court denied the motion to proceed with the appeal, holding that it was the duty of Petition to file a timely notice of appeal, and he did not establish good cause for his failure to do so. View "McDaniel v. Hobbs" on Justia Law