Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Appellant's sentence was enhanced for committing the crimes within 1000 feet of a park. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging (1) trial counsel had been ineffective, (2) the trial court erred in denying his motions for continuance and for appointment of new counsel, (3) he was entitled to more jail-time credit than he was given in the judgment-and-commitment order, and (4) his sentence was illegal. The circuit court denied Appellant's first, second, and fourth claims but left open the third claim pending the court's determination of how much jail-time credit Appellant was due. The Supreme Court dismissed Appellant's appeal and declared the motion Appellant filed related to the appeal moot, holding that the circuit court did not err in its judgment and that Appellant could not prevail if his appeal were allowed to proceed. View "Lewis v.State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery, misdemeanor theft of property, and felony theft of property. Appellant subsequently filed a pro se petition for writ of habeas corpus, asking that the videotape that showed the robbery of a gas station, which was one of the robberies of which Appellant was convicted, should be "tested." Appellant's petition was denied. The Supreme Court dismissed Appellant's appeal and declared the motion Appellant filed in relation to the appeal moot, holding that Appellant could not prevail if his appeal were allowed to proceed, as Appellant's petition was little more than a bare allegation of innocence with no showing that there was good cause to order further scientific testing of evidence. View "Hutcherson v. State" on Justia Law

Petitioner was charged by felony information filed in March 2011 with the December 2001 rape of his then-thirteen-year-old stepdaughter. At the time of the alleged rape, the statute of limitations provided that a prosecution for rape must be commenced within six years of the commission of the rape. However, a savings provision in effect at the time extended the statute of limitations for an unreported rape for up to six years beyond the victim's eighteenth birthday. Petitioner filed a motion to dismiss the rape charge for lack of jurisdiction. The circuit court denied the motion, finding that the victim's teacher called the Child Abuse Hotline in 2005 to report the sexual abuse but that there was no proof that the Hotline had referred the call to any law enforcement agency, which allowed application of the savings statute. Petitioner subsequently filed a petition for an extraordinary writ prohibiting the circuit court from trying him for rape because the statute of limitations had expired. The Supreme Court denied the writ, concluding that Petitioner failed to demonstrate he was clearly entitled to an extraordinary writ in this case. View "Morris v. Weaver" on Justia Law

Appellant was convicted in 2011 on charges of third-degree battery and rape and sentenced to an aggregate sentence of 240 months imprisonment. Appellant subsequently filed a petition for writ of habeas corpus. Appellant was first charged in 1997 with the crimes reflected in the judgment challenged in the habeas petition. In 1998, Appellant entered a negotiated plea to those charges. In 2001, the circuit court found the judgment entered on the plea imposed an illegal sentence and granted a petition for writ of habeas corpus on that basis. The prosecuting attorney refiled the original charges, and, following a jury trial, the circuit court entered a judgment reflecting the sentence Appellant now served. In denying Appellant's habeas corpus petition, the circuit court found the issues Appellant raised had previously been settled under the law-of-the-case doctrine or were not cognizable as trial-level error. The Supreme Court affirmed, holding (1) the law-of-the-case doctrine applied to some of Appellant's arguments; (2) Appellant's argument concerning a speedy-trial violation failed because the claim was not cognizable in proceedings for a writ of habeas corpus; and (3) the Court was precluded from considering Appellant's final argument raised for the first time on appeal. View "Kelly v. Norris" on Justia Law

After a jury trial, Defendant was convicted of four counts of rape for which he received four consecutive terms of life imprisonment. The victim was less than fourteen years old when the rapes were committed. Defendant appealed, contending that the evidence was not sufficient to support three of the rape convictions. Because Defendant received a sentence of life in prison, the Supreme Court reviewed the record for all objections, motions, and requests that were decided adversely to Defendant. The Court found no prejudicial error, holding that substantial evidence supported Defendant's convictions for rape, as the testimony of a rape victim, standing alone, is sufficient to support a conviction if the testimony satisfies the statutory elements of rape. View "Christian v. State" on Justia Law

Defendant entered a conditional plea of guilty to driving without a driver's license. Defendant reserved the right to appeal the circuit court's denial of his motion to suppress evidence found in what he claimed was an illegal stop. Defendant was stopped for operating an unsafe motor vehicle when the arresting officer noticed a windshield crack on the vehicle Defendant was driving. Defendant appealed, arguing, among other things, that the traffic stop was based entirely on "profiling" and was thus illegal. The Supreme Court affirmed, holding (1) a windshield with a crack running from roof post to roof post across the driver's field of vision is the type of "safety defect" contemplated by Ark. Code Ann. 27-32-101(a)(2)(A), and therefore, the arresting officer's assessment that Defendant's cracked windshield constituted a safety defect was not a mistake of Arkansas law; and (2) the trial court did not err in crediting the arresting officer's testimony, and therefore, the Court had no reason to question the officer's credibility. View "Villanueva v. State" on Justia Law

Appellant was convicted of second-degree murder, endangering the welfare of a minor, and fleeing. Appellant received a total sentence of 1188 months' imprisonment. Appellant filed a notice of direct appeal, which remained pending in the court of appeals. Two days later, Appellant filed a petition for postconviction relief. The circuit court dismissed the petition, concluding that it lacked jurisdiction to consider the petition while Appellant's direct appeal of his conviction was pending. The Supreme Court dismissed Appellant's appeal of the denial of his petition for postconviction relief and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant's petition for postconviction relief was untimely, and therefore, the trial court and appellate court lacked jurisdiction to grant relief. View "Slocum v. State" on Justia Law

Appellant entered a plea of guilty in Howard County to breaking or entering and theft of property. While incarcerated, Appellant filed a pro se petition for writ of habeas corpus contending that Howard County did not have jurisdiction in this case because the information and warrants leading to Appellant's arrest were not signed by the circuit judge and stamped with the judge's seal and that the arrest was illegal. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant did not establish that a writ of habeas corpus was warranted in this case, as Appellant failed to assert allegations that were cognizable in a habeas proceeding. View "Roberson v. State" on Justia Law

After a jury trial, Appellants Ricky Bruner and Melissa Workman were convicted of first-degree battery against their son. Bruner was sentenced to forty years in prison, and Workman received a sentence of life imprisonment. The Supreme Court affirmed Appellants' convictions and sentences, holding that the circuit court (1) did not abuse its discretion in excluding evidence of Appellants' mental condition; (2) did not err by failing to give an instruction on the lesser-included offense of third-degree battery; and (3) did not err in refusing to give a proffered jury instruction defining the phrase "manifesting extreme indifference to the value of human life." View "Bruner v. State" on Justia Law

Appellant entered a conditional plea of guilty to one count of commercial burglary, reserving his right to appeal the denial of his motion to dismiss for a speedy-trial violation. On appeal, Appellant argued that the circuit court erred by denying his motion to dismiss because the State allegedly intentionally delayed the start of his twelve-month speedy-trial period by refusing to serve the arrest warrants issued for him when they knew he was incarcerated. The Supreme Court affirmed, holding that Appellant's argument had no merit, as the speedy-trial period begins to run on the date of arrest or service of summons and not when an arrest warrant has been issued, and therefore, the speedy-trial period had not yet expired at the time Appellant filed his motion to dismiss. Therefore, the circuit court properly denied the motion to dismiss. View "Robinson v. State" on Justia Law