Justia Civil Rights Opinion Summaries

Petitioner was found guilty by a jury of possession of a firearm by a felon as a result of his involvement in a shooting outside a nightclub. The court of appeals affirmed. Petitioner subsequently sought a writ of error coram nobis or certiorari so the trial court could consider a belated Ark. R. Crim. P. 37 petition on the question presented and for interpretation of new federal precedent found in Martinez v. Ryan and clarification of application to Arkansas law and procedure. The Supreme Court denied the petition, holding that Petitioner failed to state a ground on which a writ of error coram nobis or certiorari was warranted. View "Robinson v. State" on Justia Law

Pursuant to a negotiated plea agreement, Appellant pled guilty in 1997 in the Pope County circuit court to criminal charges. He was sentenced to 120 months' incarceration. In 2011, Appellant was again convicted of criminal charges, this time in Pike County Circuit Court. Later that year, the State filed a petition pursuant to the Inmate Reimbursement Act, seeking reimbursement of the costs of Appellant's incarceration. Funds were taken from Appellant's inmate account and placed in the Pope County circuit court's registry pending the outcome of the action. Appellant filed a motion to dismiss, and the State replied to the motion and filed a motion to transfer the action to the Pike County circuit court. The circuit court denied Appellant's motion to dismiss and granted the State's motion to transfer the action. Appellant sought an appeal and requested to proceed in forma pauperis. The Supreme Court denied the motion to proceed forma pauperis, as there was not a final, appealable order entered in this case, and it was clear Appellant could not prevail if the matter were allowed to proceed. View "Plunk v. State" on Justia Law

Appellant was convicted of battery in the third degree and sentenced to twelve months' probation. He was further ordered to pay costs and fees, as well as restitution of $40,304, "less any payments received through insurance claim and/or civil recovery from defendant." The State later filed a petition for revocation of Appellant's probation, alleging that, while Appellant's insurance had paid $29,595 toward the victim's civil claim, a balance of $10,709 remained, toward which Appellant had failed to make any payments. After a hearing, the circuit court extended Appellant's probation and directed him to make restitution of $10,709. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant had not fulfilled his restitution obligation. View "Moore v. State" on Justia Law

Pursuant to a negotiated plea agreement, Appellant pled guilty to manufacturing a controlled substance, two counts of possession of drug paraphernalia with the intent to manufacture methamphetamine, and failure to appear. Appellant subsequently filed a petition for writ of habeas corpus and a motion to proceed in forma pauperis. The circuit court granted the motion but denied the petition. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that because none of the allegations contained in Appellant's petition provided a basis for finding that a writ of habeas corpus should issue, it was clear Appellant could not prevail if his appeal were allowed to proceed. View "McHaney v. Hobbs" on Justia Law

Appellant lodged an appeal in the Supreme Court from an order of the circuit court that denied his petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. Appellant filed a motion to be provided a copy of the record and a motion to stay the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding (1) to the extent Appellant's claims were cognizable under Ark. R. Crim. P. 37.1, his request for relief was properly treated as a petition under Rule 37.1 and was subject to the time limitations associated with the rule; and (2) because Appellant's petition was not timely filed under either Rule 37.1 or section 16-90-111, the trial court did not err in concluding that the petition was not timely. View "Hickman v. State" on Justia Law

A jury convicted Appellant of possession of a controlled substance with intent to deliver methamphetamine and sentenced him to life imprisonment without parole. Appellant challenged his conviction on the basis that his right to effective counsel was violated by a conflict of interest and that the trial court abused its discretion in allowing evidence of gang affiliation during the sentencing hearing. The Supreme Court affirmed, holding (1) the Court was precluded from reviewing Appellant's ineffective assistance claim because he did not raise it at the trial court level; and (2) Appellant's claim that the trial court erred in admitting evidence of gang affiliation during the sentencing phase of the trial was also not preserved for appeal. View "Guevara v. State" on Justia Law

Appellant was convicted of four counts of capital murder and one count of kidnapping. On appeal, Appellant contended (1) the State's use of inconsistent prosecutorial theories in his trial and in the separate trial of a co-defendant denied him due process of law; and (2) because the police failed to inform him that he was under no legal obligation to comply with their request to speak with them, Ark. R. Crim. P. 2.3 was violated and any subsequent statements to police should have been suppressed. The Supreme Court affirmed, holding (1) the circuit court did not err in denying Appellant's motion to prohibit the prosecution from arguing contradictory theories of the case; and (2) the circuit court's denial of Appellant's motion to suppress his statements was not clearly against the preponderance of the evidence. View "Green v. State" on Justia Law

Appellant appealed an order of the circuit court convicting him of rape for digitally penetrating a seven-year-old child and sentencing him as a habitual offender to life imprisonment. For reversal, Appellant argued that the circuit court erred in denying his motion for directed verdict and that the circuit court abused its discretion in denying his motion in limine to exclude the testimony of witnesses offered pursuant to Ark. R. Evid. 404(b). The Supreme Court affirmed, holding (1) there was substantial evidence to support Appellant's conviction, and therefore, the circuit court properly denied Appellant's motion for directed verdict; and (2) the circuit court did not err in admitting three witnesses' testimony pursuant to Rule 404(b). View "Fields v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder, first-degree murder, and capital murder. Appellant received an aggregate sentence of life imprisonment without parole. Appellant appealed, contending that the circuit court abused its discretion in excluding fingerprint and trace-DNA evidence of unknown persons found at the crime scene and at the residence of one of the victims. The Supreme Court affirmed the judgment and commitment order after noting that the circuit court correctly found that the evidence Appellant intended to offer was too speculative because it related only to unknown third persons and in so ruling, holding that the circuit court did not abuse its discretion in excluding the proffered evidence pursuant to the Zinger test, which requires that a direct connection with the crime on trial is required. View "Birts v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to a term of life imprisonment without parole. Appellant's sole argument on appeal was that he did not knowingly and intelligently waive his right to counsel because the circuit court failed to adequately warn him about the dangers and disadvantages of self-representation. Specifically, Appellant asserted that the deficiencies the Supreme Court observed in Bledsoe v. State were equally present in this case and required reversal of his conviction. The Supreme Court affirmed the conviction and sentence, holding that, on the record, Appellant made his decision with open eyes, choosing to forego the right to counsel with full awareness of the dangers and pitfalls associated with self-representation. View "Walton v. State" on Justia Law