Justia Civil Rights Opinion Summaries

Articles Posted in Arkansas Supreme Court
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Petitioner was convicted of eleven counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The court imposed an aggregate sentence of 108 months' imprisonment. Petitioner did not appeal the sentencing order and subsequently sought leave to proceed with a belated appeal. In his motion, Petitioner asserted that his appointed attorney did not provide effective assistance of counsel and that the evidence was insufficient to sustain the judgment. The Supreme Court denied the motion, holding that Petitioner did not demonstrate good cause to permit him to proceed with a belated appeal, as Petitioner's allegation concerning his attorney's effectiveness at trial and his claim of actual innocence were not matters to be addressed in a proceeding for a belated appeal. View "Davis v. State" on Justia Law

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Petitioner was convicted of three counts of rape and three counts of terroristic threatening. The convictions were affirmed on direct appeal. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecution withheld evidence of reports and transcripts of the victims' statements and that this was a violation of Brady v. Maryland. The Supreme Court denied the writ, holding that Petitioner did not establish a Brady violation because Petitioner's claim that the materials were not made available to his defense did not appear meritorious. View "Sparks v. State" on Justia Law

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Appellant was convicted of rape and sentenced to 300 months' imprisonment. The Supreme Court affirmed Appellant's conviction and sentence, holding that the circuit court did not err in (1) denying Appellant's motion in limine to suppress statements he made to his psychotherapist and the medical records pertaining to his treatment, as the argument was not preserved for appellate review; and (2) granting the State's motion in limine to exclude any instance of abuse that might have occurred after the victim turned fourteen years old, as Appellant failed to preserve his argument that the evidence would have been relevant and admissible to impeach the victim's credibility. View "Riley v. State" on Justia Law

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Petitioner was convicted of two counts of rape and sentenced to an aggregate sentence of 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel at trial. The Supreme Court denied the petition, holding that Petitioner's allegation was outside the purview of a coram-nobis proceeding, and to the extent that Petitioner may have intended his claims to be an attack on the sufficiency of the evidence or the credibility of witnesses, such issues were also not cognizable in coram-nobis proceedings. View "McDaniels v. State" on Justia Law

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Appellant was convicted of delivery of a controlled substance and sentenced to an enhanced sentence of forty years' imprisonment and a fine. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief and, later, a motion to correct an illegal sentence. Both requests were denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus raising double-jeopardy claims. The circuit court denied the petition. Appellant appealed and filed with the Supreme Court a motion for extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant's claims were not cognizable in a petition for habeas corpus. View "Khabir v. Hobbs" on Justia Law

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Appellee was charged with felony possession of drug paraphernalia and misdemeanor possession of a controlled substance. The charges stemmed from a probationary search of the bedroom he rented and sometimes shared with his girlfriend, a probationer. Appellee moved to suppress the evidence on the basis that the warrantless search of his bedroom was conducted without his consent, without probable cause, and without exigent circumstances. After a hearing, the circuit court ruled that the State failed to prove the reasonableness of the warrantless, probationary search as to Appellee because Appellee did not expressly consent to the search. The Supreme Court dismissed the State's appeal, holding that resolution of this case turned on application of its unique facts to the law, and therefore, the correct and uniform administration of the criminal law did not require the Court's review. View "State v. Myers" on Justia Law

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Appellee's husband, a parolee, resided with Appellee. After a parole agent determined that a parole search of the residence was warranted, the parole officer and other police officers searched the residence. Appellee was subsequently charged with possession of methamphetamine and possession of drug paraphernalia. Prior to trial, Appellee filed a motion to suppress, alleging (1) police officers conducted the search without a warrant, without consent, and without reasonable cause; and (2) her arrest exceeded the authority of the parole officer. The circuit court granted Appellee's motion to suppress, ruling that reasonable grounds for a parole search must exist and more-than-minimal police involvement was necessary in the parole search at issue. The Supreme Court dismissed for lack of a proper State appeal where (1) the State's appeal involved only the application of a rule or statute; and (2) because the trial court acted on a mixed question of law and fact, the matter was not appealable by the State. View "State v. Jones" on Justia Law

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After a jury trial, Petitioner was found guilty of first-degree murder and sentenced to 600 months' imprisonment. The judgment was affirmed on direct appeal. Petitioner then sought postconviction relief in the trial court. The petition was dismissed on the ground it was not timely filed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the evidence was not sufficient to sustain the judgment-and-commitment order. The Supreme Court denied the petition, holding that Petitioner's claim was not cognizable in a coram-nobis proceeding. View "Sims v. State" on Justia Law

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Appellant was convicted by a circuit court jury of one count of rape and one count of second-degree sexual assault. Appellant was sentenced to life imprisonment, an additional eighteen years, and $10,000 fine. Appellant appealed, alleging that the circuit court abused its discretion by overruling his objections to the prosecution's closing argument during the guilt phase of his trial. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Appellant's objections to the prosecution's closing argument, as the prosecution's closing argument did not constitute error and was in response to the credibility challenges made to its witnesses. View "Stewart v. State" on Justia Law

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Appellant was found guilty of rape by a jury in the circuit court and was sentenced to 300 months' imprisonment. The court of appeals affirmed as modified. Appellant's subsequent petition for postconviction relief was denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus, contending (1) he had new scientific evidence to prove his innocence, (2) his trial attorney was ineffective, (3) he was denied due process of law by trial errors and the failure of the prosecution to comply with discovery requests and the reliance by the prosecution on perjured testimony to gain the conviction, and (4) the evidence was insufficient to sustain the judgment. The circuit court dismissed the petition. The Supreme Court dismissed the appeal and declared the motion related to the appeal moot, holding that because Appellant failed to state cognizable claims, he did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Girley v. Hobbs" on Justia Law