Justia Civil Rights Opinion Summaries

Petitioner was convicted of capital murder and sentenced to the death penalty. After a mandatory review of Petitioner's conviction and sentence, the Supreme Court issued a mandate affirming the trial court's judgment. Petitioner subsequently petitioned the Supreme Court to recall its mandate and also filed a petition to reinvest the circuit court with jurisdiction to consider a petition for writ of error coram nobis. The Supreme Court denied both petitions, holding (1) Petitioner failed to demonstrate extraordinary circumstances resulting in a defect in the appellate process that warranted recall of the Court's mandatory-review mandate; (2) Petitioner failed to demonstrate that a recall of a the mandatory-review mandate was necessary based on Petitioner's allegation that there was an alleged breakdown in the postconviction process; and (3) Petitioner failed to proceed with diligence in pursuing coram nobis relief. View "Roberts v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to the death penalty for the murder of a twelve-year-old. Following his conviction, Petitioner filed a waiver of his right to appeal and postconviction review. Petitioner subsequently sought to rescind that waiver and asserted several bases on which the Supreme Court should reopen his postconviction proceedings and reinvest jurisdiction in the circuit court. The Supreme Court granted Petitioner's motion, holding that the Court previously failed to ensure that Petitioner was indeed competent to waive his rights to postconviction relief, and such extraordinary circumstances required the Court to reopen the proceedings. View "Roberts v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole. Appellant subsequently filed a petition for writ of habeas corpus, arguing that his life sentence was illegal because he was a minor when the crime was committed. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared Appellant's motions for appointment of counsel and extension of brief time moot, holding that Appellant failed to demonstrate that his sentence was illegal under Miller v. Alabama, and therefore, it was clear that Appellant could not prevail if his appeal were allowed to proceed. View "Murry v. Hobbs" on Justia Law

Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Forty-four months after the judgment of conviction had been entered against him, Appellant filed a petition under Act 1780 of 2001 to vacate or set aside the judgment. The circuit court denied the petition. Appellant appealed and requested an extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion for extension of time moot, holding that the decision to deny the requested relief was not clearly erroneous, as (1) Appellant failed to rebut the presumption against timeliness on his request for DNA testing; and (2) none of the other claims that Appellant raised were grounds for relief under Act 1780. View "Foster v. State" on Justia Law

After a jury trial, Defendant was convicted of capital felony murder and aggravated robbery, with a firearm enhancement on each count. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. The Supreme Court affirmed, holding (1) the evidence supported a conclusion that Defendants death occurred during the commission of an aggravated robbery under circumstances manifesting extreme indifference to the value of human life, and thus Defendant's convictions were supported by sufficient evidence; and (2) Defendant failed to preserve for appeal his final two arguments, including his claim that the circuit court erred in prohibiting defense counsel from informing the jury that Defendant would be automatically sentenced to life without parole if convicted of capital felony murder. View "Bradley v. State" on Justia Law

In 1997, Petitioner was convicted of multiple felony offenses. An aggregate term of life imprisonment was imposed. Petitioner later attempted to pursue postconviction relief, but his efforts were dismissed. In 2012, Petitioner filed a pleading entitled "motion to vacate a void judgment" in which he alleged the trial court had lacked subject-matter jurisdiction to convict him. Petitioner subsequently filed a petition for writ of mandamus asking that the Supreme Court direct the circuit court to enter an order disposing of Petitioner's 2012 motion. The State responded that the circuit court had in fact acted upon Appellant's petition and appended to its response a copy of the circuit court's order denying the petition. The Supreme Court therefore declared the petition for writ of mandamus moot. View "Watts v. Griffen" on Justia Law

Upon stopping Defendant and boarding his boat to perform a safety check, an enforcement division officer of the Arkansas Game and Fish Commission concluded that Defendant was under the influence of alcohol. Defendant entered a no-contest plea to boating while intoxicated. Defendant appealed, alleging that the Game and Fish officers had no authority to stop and arrest him and that there was a lack of probable cause for the stop. The circuit court reversed, holding that the stop of Defendant's vehicle was unreasonable under the circumstances and violated Defendant's Fourth Amendment rights. The Supreme Court affirmed, holding that the practice of safety-check stops by law-enforcement officers in this case violated the Fourth Amendment. View "State v. Allen" on Justia Law

After a jury trial, Petitioner was found guilty of attempted first-degree murder and first-degree battery. Petitioner subsequently filed a timely pro se petition for postconviction relief, which the trial court denied. Petitioner did not timely file a notice of appeal from the order and sought leave to proceed with a belated appeal. The Supreme Court granted the motion, holding that Petitioner established good cause for his failure to file a timely notice of appeal, as nothing in the record suggested that Petition was properly notified that the order denying his postconviction relief petition had been entered, and because the record was silent, the Court must assume that Petitioner was not properly notified. View "Robinson v. State" on Justia Law

A disciplinary action was imposed upon Appellant, an inmate of the Arkansas Department of Correction (ADC). Appellant filed a petition for judicial review and declaratory judgment seeking to challenge the dismissal of his grievance concerning the disciplinary action, the application of an administrative directive by prison officials, and policies he asserted were in violation of contractual obligations of the ADC concerning his conduct in regard to hobby crafts while incarcerated. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court correctly determined that Appellant's petition did not set forth facts to show deprivation of a liberty interest and, as a result, Appellant failed to sustain a claim under the Arkansas Administrative Review Act to support a judicial review of the ADC's decision. View "Renfro v. Smith" on Justia Law

Appellant was charged with capital murder and subsequently entered a negotiated plea of guilty to first-degree murder and received a sentence of 420 months' imprisonment. Appellant filed a timely pro se petition for postconviction relief, setting forth three claims for relief, each asserting that his trial counsel was ineffective. The trial court denied the petition without a hearing. The Supreme Court affirmed the order, holding that it was clear from the face of the petition that the allegations in the petition were without merit, as Appellant failed to allege any facts to support a demonstration of prejudice concerning his claims. View "Pennington v. State" on Justia Law