Justia Civil Rights Opinion Summaries

Appellant Seafin Sandoval-Vega entered a guilty plea to capital murder and was sentenced to life imprisonment without parole. Appellant filed a petition for postconviction relief, which the trial court denied without a hearing. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant's claim of ineffective assistance of counsel concerning counsel's failure to have a court-ordered mental evaluation entered of record required a hearing as the report was crucial to Appellant's claim that he was not competent and the trial court exceeded its jurisdiction in taking Appellant's guilty plea before the questions about Appellant's competency were resolved; and (2) the remaining issues Appellant raised were without merit. Remanded to the trial court for new proceedings to provide a ruling and findings on the issue of the mental evaluation.

Appellant Dennis Riley entered a negotiated plea to charges of capital murder and aggravated robbery and received consecutive sentences of life imprisonment without parole on each count. Appellant then filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant did not make a showing that counsel manipulated him into accepting the plea agreement, but (2) the trial court's findings were insufficient for appellate review on the issue of whether counsel's strategic decision to recommend the plea offer was based upon reasonable professional judgment, and it appeared that a hearing was was warranted on the claim. Remanded in part.

Petitioner Steven Pinder was found guilty of two counts of rape and was sentenced to life imprisonment. Petitioner subsequently filed a petition with the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecutor withheld certain evidence from the defense during trial in violation of Brady v. Maryland. The Supreme Court denied the petition, holding that all of the claims raised by Petitioner were known to him at trial, were not in existence at the time of trial, had not been diligently advanced, or were otherwise noncognizable.

Appellant Jeff Morgan was found guilty by a jury of kidnapping, a Class Y felony, and second-degree battery and was sentenced as a habitual offender to an aggregate term of life imprisonment. Appellant subsequently filed a pro se petition for writ of habeas corpus. The petition was denied without a hearing. Appellant appealed and filed a motion seeking photocopies of his brief-in-chief at public expense. The Supreme Court dismissed the appeal and declared the motion moot, holding that the circuit court did not err in denying the relief sought because Appellant's petition did not state a basis to warrant issuance of the writ.

A jury found Appellant Terry Matthews guilty of aggravated robbery. Appellant subsequently filed a petition for postconviction relief, arguing ineffective assistance of counsel at trial. The circuit court denied the petition. The Supreme Court affirmed, holding, inter alia, that (1) counsel was not ineffective for failing to raise a speedy-trial argument because Appellant was not denied the right to a speedy trial; (2) counsel was not ineffective by not objecting to testimony regarding Appellant's history of drug and alcohol abuse because counsel's decision was the product of reasonable professional judgment; and (3) counsel was not ineffective for failing to object during closing argument because Appellant did not establish that he was denied a fair trial by the failure to object.

Appellant James Lowe entered a plea of no contest to a charge of first-degree sexual abuse. More than a decade later, Appellant pled guilty to a charge of failing to register as a sex offender. Appellant subsequently filed a petition for writ of habeas corpus, arguing (1) his sentence in the sexual-abuse case was illegal because it exceeded the maximum sentence allowed, and there was a speedy-trial violation; and (2) his sentence in the failure-to-register case was a direct result of the first illegal sentence and, thus, was also illegal. The circuit court denied Appellant's petition, finding that he failed to demonstrate a basis for habeas relief. The Supreme Court affirmed, holding that Appellant could not demonstrate that he was being illegally detained as a result of his sentence in the sexual-abuse case because (1) he completed his sentence before he filed his habeas petition, and (2) petitioners cannot obtain habeas relief from a sentence that has already been served in full.

A jury convicted Appellant Melvin Lockhart of first-degree murder and theft of property. The court of appeals affirmed, holding that because Appellant did not move for a directed verdict on the offense of first-degree felony murder, the court was precluded from reaching the issue of sufficiency of the evidence. Appellant subsequently filed a motion for postconviction relief, alleging, among other things, that his trial counsel was ineffective for failing to move for a directed verdict. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding the circuit court properly denied Appellant's petition where (1) Appellant did not demonstrate that he was prejudiced by trial counsel's error in failing to make a directed-verdict motion; and (2) Appellant failed to show that trial counsel prejudiced the defense with respect to Appellant's not testifying at trial.

Appellant Gregory Holt was convicted of aggravated residential burglary and first-degree domestic burglary. Appellant was sentenced to life imprisonment on the aggravated residential burglary charge and forty years on the first-degree domestic battery charge, with the sentences to run concurrently. The Supreme Court affirmed, holding (1) the circuit court correctly denied Appellant's directed-verdict motion as there was sufficient evidence to support his aggravated residential burglary conviction; (2) the circuit court did not abuse its discretion in permitting Appellant to be shackled in front of the jury as the restraints were reasonably necessary to maintain order and security in the courtroom; and (3) Appellant's remaining arguments were not preserved for appellate review.

Appellant Lamarcus Christopher entered a plea of guilty to various drug offenses. Six months later, Appellant pled guilty to possession of a firearm by certain persons. More than a year later, the circuit court entered two amended judgments on each of the two cases, altering only the name of the offenses to include that Appellant was charged "as habitual." Appellant's sentences were not altered in either amendment. Appellant subsequently filed a pro se petition for writ of habeas corpus, arguing (1) he had not been properly notified that he was being charged as a habitual offender, (2) the amended judgment conflicted with the sentence as ordered in open court where he was not pronounced a habitual offender, and (3) but for this misrepresentation, he would not have pled guilty to the charges. The circuit court denied Appellant's petition with prejudice. The Supreme Court affirmed, holding that the circuit court was correct to deny Appellant's petition because he made neither a claim that his judgment-and-commitment order was invalid on its face nor a claim that the sentencing court was without jurisdiction.

Appellant Ke'ondra Chestang, an inmate incarcerated in the Arkansas Department of Correction (ADC) at a facility in Lincoln County, filed a petition for writ of habeas corpus in the Lincoln County circuit court. The circuit court denied the petition. Appellant then filed motions seeking an order directing the circuit clerk in Lincoln County to provide him with certain documents and an extension of time in which to file his brief. At that point Appellant had been transferred to an ADC facility located in Jefferson County. The Supreme Court dismissed Appellant's appeal and declared the motions moot, holding that because Appellant was in Jefferson County when he filed the motions, the Lincoln County circuit court could no longer grant the relief requested by Appellant because it did not have jurisdiction.