Justia Civil Rights Opinion Summaries

Appellant was imprisoned for possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Appellant subsequently filed in the circuit court of the country where he was imprisoned a pro se petition for writ of habeas corpus, claiming (1) his sentence was illegal because it was improperly enhanced using an out-of-state conviction, and (2) counsel was ineffective for failing to challenge the imposition of the enhancement. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in its judgment, as (1) claims of ineffective assistance of counsel are not cognizable in habeas proceedings; and (2) Appellant failed to provide some evidence in support of his illegal sentence claim. View "Darrough v. State" on Justia Law

Appellant was convicted of first-degree murder and was sentenced to 420 months' imprisonment. Appellant subsequently filed a petition for postconviction relief, which the trial court denied. Appellant appealed and filed motions seeking to obtain documents from the prosecutor and to request an extension of time in which to file his brief. The Supreme Court (1) denied the motion to obtain documents, as Appellant failed to demonstrate that the documents could be utilized in preparing his brief to the Court; and (2) granted the motion for extension of time, as Appellant had not received a ruling on his motion to obtain documents and the circumstances of Appellant's incarceration caused delay in the brief's preparation. View "Plessy v. State" on Justia Law

After a jury trial, Defendant was convicted of capital murder, criminal attempt to commit capital murder, and aggravated robbery. Defendant subsequently filed a pro se petition for postconviction relief. The circuit court denied the requested relief. The Supreme Court affirmed, holding that the circuit court did not err in (1) failing to hold a hearing on Defendant's petition; (2) concluding that there was no merit to Defendant's argument that he was subjected to double jeopardy by being convicted of both capital murder and aggravated robbery; and (3) concluding that none of Defendant's claims of ineffective assistance of counsel had merit. View "Jackson v. State" on Justia Law

Appellant was convicted of capital murder and sentenced to life imprisonment without the possibility of parole. Appellant subsequently filed a petition for writ of habeas corpus. The trial court denied the petition for lack of jurisdiction based on its findings that Appellant was not incarcerated within the jurisdiction of the court. The Supreme Court reversed, holding that the trial court erred in finding that it lacked jurisdiction, as Appellant sought habeas relief under Act 1780 of 2001. Therefore, Appellant's petition was appropriately filed within the jurisdiction of the court in which he had been convicted, without regard to the place of his incarceration. View "Clemons v. State" on Justia Law

Appellant pled guilty to two counts of theft of property valued at over $2,500 for the theft of lottery tickets and one count of felony fraud for the cashing of the lottery tickets. The circuit court ordered that Appellant pay restitution to Mallard Express and to the Arkansas Lottery Commission. Appellant appealed, arguing that the order of restitution amounted to double restitution and that the State had failed to show that the Commission had suffered an economic loss. The Supreme Court dismissed the appeal, holding (1) the rules did not allow Appellant to appeal from her guilty plea, and (2) none of the exceptions to the rule that a defendant cannot appeal from a guilty plea applied. View "Spires v. State" on Justia Law

Appellant entered a negotiated plea of guilty to aggravated robbery and theft of property. Appellant's subsequent motion to vacated the judgment against him was denied. More than six years from the date of Appellant's guilty plea, Appellant filed a petition to correct an illegal sentence, challenging the application of the habitual-ofender enhancement to his sentence. The circuit court denied the petition. Appellant appealed but did not tender a timely brief-in-chief. Before the Supreme Court was Appellant's motion to file belated brief in this appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant could not prevail if his appeal were allowed to proceed, as the habitual-offender issue was not timely and Appellant's sentence was clearly within the prescribed statutory range. View "Redus v. State" on Justia Law

A judgment was entered reflecting that Appellant entered a plea of guilty to delivery of a controlled substance. Appellant was placed on probation for 120 months. An amended judgment-and-commitment order was entered seven days later. Later that year, a judgment-and-commitment order was entered reflecting that Appellant's probation had been revoked and that she had been sentenced to imprisonment. More than eight months after the original and amended judgments had been entered and four months after the order revoking probation had been entered, Appellant filed a pro se petition for postconviction relief. The petition was dismissed on the grounds that it was not timely filed and did not state a basis for postconviction relief. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that Appellant's petition was untimely filed. View "Murphy v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder and possession of a firearm by certain persons. Appellant subsequently filed a pro se petition for postconviction relief. Circuit Judge Susan Hickey scheduled a hearing on the petition, but prior to the date of the hearing, Judge Hickey resigned her seat as judge. On November 21, 2011, Circuit Judge Hamilton Singleton denied Appellant's petition without a hearing. Appellant filed two motions for reconsideration, requesting the circuit court set aside its order and hold a hearing on the petition as originally scheduled by Judge Hickey. Appellant's first and second motions were denied. On March 28, 2012 Appellant filed a notice of appeal from the circuit court's order denying his petition for postconviction relief. The Supreme Court dismissed Appellant's appeal, holding that it was untimely in this case. View "Lovett v. State" on Justia Law

Appellant was an inmate in the Department of Correction serving a life sentence. Appellant filed a complaint against the governor, the chairman of the parole board, and the chairman of the board of correction seeking a declaratory judgment, injunctive relief against Defendants for civil-rights violations, and relief as a taxpayer for an illegal exaction based on claims concerning the procedures for submission of applications for clemency. The circuit court dismissed the complaint for failure to state a claim upon which relief may be granted. Appellant appealed and filed motions related to his appeal. The Supreme Court denied the motions and affirmed the circuit court's dismissal of the complaint, holding that the court did not abuse its discretion in concluding that Appellant failed to state a claim on the three bases that Appellant raised in this appeal. View "Holloway v. Beebe" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder and first-degree battery and failure to stop after an accident with injury or death. Appellant appealed, contending that the trial court erred by refusing to instruct the jury on the offense of felony manslaughter, which he argued was a lesser-included offense of felony murder. In so arguing, Appellant contended that although Perry v. State and Hill v. State supported the trial court's ruling, those cases ignored Ark. Code Ann. 5-2-203(b). The Supreme Court affirmed, holding (1) the Court would not accept Appellant's invitation to overrule Perry and Hill; and (2) the Court's felony-murder jurisprudence is in concert with the legislature's mandate stated in section 5-2-203(b). View "Holian v. State" on Justia Law