Justia Civil Rights Opinion Summaries

In 2009, judgment was entered reflecting that Petitioner had been found guilty of multiple felony offenses. He was sentenced as a habitual offender to an aggregate term of 504 months' imprisonment. The court of appeals affirmed. The court of appeals' mandate was issued on June 2, 2010. On January 20, 2012, more than eighteen months after the mandate was issued, Petitioner filed a pro se petition for postconviction relief. The trial court denied the petition on the ground that it was untimely filed. The Supreme Court dismissed Petitioner's appeal and declared the motion related to the appeal moot, holding that the trial court did not err in denying the petition because it was untimely filed. View "Bates v. State" on Justia Law

Petitioner entered a negotiated plea of guilty to a charge of first-degree murder and was sentenced to 360 months' incarceration. Six years later, Petitioner filed a pro se petition for writ of error coram nobis, which the circuit court denied. Petitioner did not timely file a notice of appeal. Petitioner subsequently filed a pro se motion to belatedly lodge an appeal from the circuit court's order. The Supreme Court denied the petition, as Petitioner did not preserve his right to appeal the postconviction order or meet his burden of demonstrating that there was good cause for his failure to perfect his appeal in a timely manner. View "Meadows v. State" on Justia Law

Appellant appealed the decree entered by the circuit court granting the petition of Appellees, Appellant's parents, to adopt Appellant's daughter. On appeal, Appellant contended that the circuit court erred in denying her request for the appointment of counsel because, as an indigent, she was entitled to appointed counsel in a private adoption proceeding under both the federal and state Constitutions. She also argued that the circuit court's findings in support of the adoption were clearly erroneous. The Supreme Court affirmed, holding (1) Appellant's first argument was not preserved for appeal; (2) the circuit court correctly found that Appellant's consent to the adoption was not necessary; and (3) the circuit court's finding that the adoption was in the child's best interest was not clearly erroneous. View "Lucas v. Jones" on Justia Law

Appellant was convicted of capital murder and attempted capital murder and sentenced to consecutive sentences of life in prison without parole, thirty years' imprisonment, and a fifteen-year enhancement for using a firearm during the commission of the attempted capital murder. Appellant appealed his convictions and sentences based on alleged error committed by the circuit court in admitting three of his text messages into evidence. The Supreme Court affirmed, holding (1) Appellant failed to preserve his Stores Communications Act argument and his illegal-search argument based on the Arkansas Constitution for the Court's review; and (2) because there was sufficient evidence to authenticate all three text messages at issue, the circuit court did not abuse its discretion in admitting any of the three text messages at trial. View "Gulley v. State" on Justia Law

In 1982, Appellant was found guilty by a jury of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed. In 2012, Appellant filed a pro se petition for writ of habeas corpus, contending that the evidence was insufficient to sustain the judgment, that there were serious errors at trial, and that a mistrial should have been granted because the prosecution withheld material evidence. The circuit court dismissed the petition, and Appellant appealed. Before the Supreme Court were Appellant's motions for appointment of counsel and to supplement his brief and a petition for writ of certiorari to bring up additional material for the record. The Supreme Court dismissed the appeal and declared the motions and petition 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 "Fuller v. State" on Justia Law

In 1996, Appellant was convicted of rape and first-degree sexual abuse. The Supreme Court affirmed. In 2012, more than fourteen years after the judgment was affirmed, Appellant filed a pro se motion seeking a new trial, raising several claims of error. The motion was denied on the ground that it was an untimely and unverified petition for postconviction relief. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding (1) the trial court correctly treated Appellant's motion for new trial as an untimely petition for postconviction relief; (2) Appellant's claims of ineffective assistance of counsel were cognizable under Ark. R. Crim. P. 37.1 and should have been raised in a timely petition under the rule; (3) Appellant's assertions that he was denied his constitutional rights were waived; and (4) Appellant's allegation that the evidence was insufficient to sustain the judgment was not cognizable in a postconviction proceeding. View "Evans v. State" on Justia Law

Appellant appealed from the judgment and commitment order of the circuit court convicting him of criminal attempt to commit theft of property and committing a fraudulent insurance act and sentencing him to a total time of 120 months' imprisonment. Appellant appealed, asserting that the circuit court erred in denying his motion to dismiss for lack of speedy trial. The court of appeals reversed his convictions and dismissed his case with a bar to future prosecution. The State petitioned for review, which the Supreme Court granted. The Court then vacated the court of appeals' opinion and affirmed Appellant's convictions and sentence, holding that the circuit court did not err in denying Appellant's motion to dismiss. View "Eagle v. State" on Justia Law

Appellant entered a negotiated plea of guilty to the offense of rape. More than four years after the judgment had been entered, Appellant filed a motion to withdraw a guilty plea under Ark. R. Crim. P. 26.1, which the circuit court denied as untimely. Appellant appealed and filed a motion to file a belated brief, in which he sought to file a nonconforming brief that he tendered in the appeal. The Supreme Court dismissed the appeal and declared the motion moot, holding that, as the petition was untimely filed, the trial court lacked jurisdiction to grant postconviction relief, and therefore, the Supreme Court also lacked jurisdiction. View "Winnett v. State" on Justia Law

Petitioner was convicted of possession of cocaine with intent to deliver, possession of methamphetamine with intent to deliver, and maintaining a drug premises. Subsequently, Petitioner, through counsel, filed a petition that sought a writ of error coram nobis or, alternatively, a writ of certiorari or recall of the mandate. In the petition, Petitioner requested that the Supreme Court assume jurisdiction of the cause rather than reinvest jurisdiction in the trial court. The Supreme Court denied the petition, holding (1) Petitioner failed to meet the criteria necessary to grant the relief he requested; and (2) Petitioner failed to make an argument that could support an exception to the requirements for issuing any of the writs or remedies he requested. View "Turner v. State" on Justia Law

Appellant pled guilty to a charge of aggravated robbery, pursuant to a negotiated plea agreement, and was sentenced to 180 months' incarceration. Subsequently, Appellant filed a petition for postconviction relief, which was denied. No appeal was taken from that denial. Thereafter, Appellant filed a petition for writ of habeas corpus, which the circuit court denied. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal and the petition moot, holding (1) Appellant failed to demonstrate that his judgment was invalid on its face or that he was otherwise illegally detained; and (2) nothing in Appellant's other allegations would provide a basis on which a writ of habeas corpus could issue. View "Smith v. Hobbs" on Justia Law