Justia Civil Rights Opinion Summaries

Appellant lodged in the Supreme Court an appeal from three orders that denied a number of pleadings that Appellant had filed in the trial court where he was convicted of capital murder in 1995. Appellant filed his brief in the appeal, and, after that, filed a motion to introduce newly discovered evidence. The State filed its brief, and Appellant tendered a reply brief along with a motion to extend the page limit. Later, Appellant filed three more motions. The Supreme Court (1) granted the motion to extend the page limit on the reply brief; (2) denied the motions to introduce newly discovered evidence and compel; and (3) affirmed the trial court's denial of relief in the three orders.

Appellant was a prisoner serving a life sentence on a rape conviction that followed his retrial after the Supreme Court reversed and remanded for an error for not requiring the prosecutor to file a bill of particulars. In 2012, Appellant filed a petition for writ of habeas corpus in the circuit court of the county where he was incarcerated, and the circuit court dismissed the petition. Appellant lodged in the Supreme Court an appeal of the order dismissing the petition, and he filed motions seeking the appointment of counsel for the appeal and an extension of time in which to file his brief. The Court dismissed the appeal and declared the motions moot, holding that Appellant's claims were without merit and that he could not prevail on appeal.

Ten death-row inmates filed amended complaints against Appellants, the Arkansas Department of Correction (ADC) and its director, asserting several causes of action. Relevant to this appeal, the prisoners (1) asserted that the Method of Execution Act (MEA) was unconstitutional on the basis of separation of powers; (2) claimed that the use of non-FDA approved chemicals purchased from a foreign driving school violated the prohibition against cruel and unusual punishment and the prisoners' due process rights; and (3) asked for injunctive relief to enjoin the ADC from executing prisoners with the non-FDA approved chemicals. The circuit court concluded (1) the MEA was unconstitutional; and (2) prisoners' additional claims were moot because ADC had disposed of all and was unable to obtain any additional lethal chemicals from the overseas supplier. The court then enjoined ADC from using any sodium thiopental obtained in violation of any state or federal law. The Supreme Court (1) affirmed the circuit court's order to the extent it declared the MEA unconstitutional and found the additional claims were moot; but (2) reversed the circuit court's order striking language from the statute, as the entire statute was unconstitutional, and granting injunctive relief.

Appellant Brittany Mahavier appealed orders of the circuit court granting a permanent guardianship of her son to her mother, Appellee Teresa Mahavier, and declaring the Arkansas Statutes on guardianships to be unconstitutional. Appellant stipulated below that there was sufficient evidence to establish a need for the guardianship but did not agree to the guardianship so she could maintain her constitutional challenges based on equal protection and substantive due process. The Supreme Court did not address the merits of the constitutional arguments because the Attorney General was not notified of the constitutional challenges to the guardianship statutes, as required by Ark. Code Ann. 16-111-106(b), and there was not full and complete adversarial development of the constitutional issues. Accordingly, the Court reversed and remanded for compliance with the notice requirement of section 16-111-106(b).

Appellant Bobby Hatton was found guilty of first-degree terroristic threatening and second-degree domestic battery in the presence of a child. The trial court subsequently found that Appellant had violated the conditions of his probations in two other cases by committing the offenses of which he had been convicted in the first case and revoked both probations. Appeals in all three cases were consolidated. The court of appeals affirmed the judgment in the first case and revocation orders in the other two cases. Appellant subsequently filed a pro se petition for postconviction relief that encompassed all three cases. The trial court denied the petition. Before the Supreme Court were two motions filed by Appellant related to the appeal. The Court dismissed the appeal and declared the motions moot, holding that because Appellant's petition was not in compliance with Ark. R. Crim. P. 37.1, it did not act to confer jurisdiction on the trial court to consider the merits of the petition, and therefore, the Court lacked jurisdiction to consider the appeal.

Appellant was found guilty of underage driving under the influence. Appellant subsequently appealed the denial of his motion to suppress the results of his breathalyzer test, arguing that the arresting officer was acting outside of his territorial jurisdiction when he transported Appellant to a different county to perform the breathalyzer test and that the test results were thus unlawfully obtained. The Supreme Court affirmed the denial of the motion to suppress after citing with approval the reasoning employed by the Rhode Island Supreme Court in State v. Hagan, holding that the officer's actions in the present case were both reasonable and lawful, and therefore, the circuit court did not err in denying the motion.

Appellant Michael MacKool was convicted of first-degree murder and theft of property, for which a cumulative sentence of sixty years' imprisonment in the Arkansas Department of Correction (ADC) was imposed. The Supreme Court affirmed. The State subsequently filed a petition pursuant to the State Prison Inmate Care and Custody Reimbursement Act seeking reimbursement from Appellant's inmate account of a portion of the cost of housing Appellant in the ADC. After a hearing, the circuit court determined that the State was entitled to the $5016 in Appellant's inmate account, and a written order was entered that ordered deposit of that money into the state treasury. Appellant timely appealed. Before the Supreme Court was Appellant's motion to file his reply brief belatedly. The Court (1) denied the motion, as Appellant's tendered reply brief did not comply with the Court's rules; and (2) affirmed the circuit court's decision to order reimbursement from Appellant's inmate account.

Appellant Brian Jordan appealed an order of the circuit court convicting him of rape and sentencing him as a habitual offender to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err in allowing prior offenses into evidence, as the court properly found the prior convictions were more probative than prejudicial and thus admissible pursuant to Ark. R. Evid. 609; and (2) Appellant's argument that he was entitled to a new trial based upon the circuit court's comments to the jury just prior to the court's dismissal of the jury was not preserved for appeal, as Appellant did not object at the time to the statements made to the jury.

Petitioner was charged by an information with having committed three felony drug-related counts. Petitioner subsequently filed four pro se pleadings in those proceedings. Later, Petitioner filed a petition for writ of mandamus, seeking an order from the Supreme Court directing the circuit judge in his case to issue an order disposing of the pro se pleadings. The Court concluded that Petitioner simply wished some disposition of the pleadings and, more specifically, requested that a written order be entered on the record addressing the merits of his arguments concerning the court's assumption of jurisdiction in the criminal proceeding so he could seek interlocutory review. The Supreme Court denied the petition, as (1) Petitioner did not provide a record that demonstrated that issuance of the writ was appropriate; and (2) Petitioner did not establish that the trial court did not adequately dispose of the pleadings on the record or that the trial court had a duty to enter a written order that addressed the merits of his jurisdictional challenge.

Appellant Jeremiah Walton was convicted of two counts of rape and received an aggregate sentence of 300 months' imprisonment. Appellant subsequently filed a petition for postconviction relief and, on the same day, motions that sought a copy of the transcript, appointment of counsel, and leave to proceed in forma pauperis. The court granted Appellant's motion to proceed as an indigent but denied the request for counsel and the request for a copy of the transcript. The trial court later denied Appellant's petition. The Supreme Court affirmed, holding (1) the trial court did not err in denying the requests Appellant made concerning his preparations for the hearing on the petition; and (2) the trial court did not err in failing to rule on each of the claims in the petition.