Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for post conviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court correctly denied Appellant's Rule 37.1 petition.Specifically, the Court held that the circuit court (1) did not clearly err by finding that trial counsel's failure to obtain a forensic evaluation prior to Appellant's pleading guilty was not ineffective assistance; (2) did not err in finding that trial counsel was not ineffective by failing to file any pretrial motions to suppress or motions in limine before permitting Appellant to enter his plea; and (3) did not apply the wrong legal standard in ruling on Appellant's petition. View "Roos v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the writ.Appellant pleaded guilty to aggravated robbery and was sentenced to a term of imprisonment. In his petition for a writ of error coram nobis Appellant alleged that his counsel did not fully explain his parole eligibility or the effect of his prior convictions, and therefore, he was coerced into pleading guilty. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant's allegations did not rise to the level of coercion sufficient to meet his burden of establishing grounds for the writ. View "Brown v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally.Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court awarding attorney's fees to Allen Hargis following the division of Allen's military retirement account after the divorce of Allen and Lynn Harris, holding that the circuit court did not abuse its discretion by failing to conduct a hearing on the parties' respective financial abilities prior to awarding attorney's fees.After resolving the parties' dispute over the division of Allen's military retirement account following their divorce the circuit court awarded attorney's fees to Allen. On appeal, Lynn argued that the circuit court's failure to conduct a hearing prior to awarding attorney's fees infringed on her right to procedural due process under the Fourteenth Amendment. The Supreme Court affirmed, holding that the circuit court was not obligated to conduct an evidentiary hearing under the Fourteenth Amendment and that Lynn was not denied an opportunity to be heard on Allen's motion for attorney's fees. View "Hargis v. Hargis" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first degree murder, attempted first-degree murder, and a firearm enhancement, holding that the circuit court did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that his constitutional rights were violated during his cross-examination of a witness when that witness testified regarding Defendant's right to remain silent.The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling the objection to the testimony because the comment was not the type of comment prohibited by the United States Supreme Court in Doyle v. Ohio, 426 U.S. 610, 618 (1976). View "Sirkaneo v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief alleging ineffective assistance of trial and appellate counsel, holding that Petitioner's allegations were unavailing.Petitioner was convicted of first-degree felony murder, aggravated robbery, felony theft, and misdemeanor theft. The Supreme Court reversed the aggravated robbery convictions and remanded for resentencing. After resentencing, Petitioner petitioned for postconviction relief under Ark. R. Civ. P. 37, alleging that he received constitutionally deficient counsel both at trial and on direct appeal. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Petitioner's alleged errors with respect to trial counsel's performance and that Petitioner's claims of ineffective assistance of appellate counsel were without merit. View "Thompson v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's claims for postconviction relief that were raised pursuant to Ark. R. Crim. P. 37.1, holding that Appellant raised claims that were not cognizable in Rule 37.1 proceedings and failed to establish prejudice as a basis to support his ineffective assistance of counsel claims.Appellant was convicted of murder in the first degree and abuse of a corpse and sentenced as a habitual offender. Appellant filed a timely petition for Rule 37.1 relief, arguing that juror misconduct, prosecutorial misconduct, and an illegal search violated his right to due process and that he received ineffective assistance of counsel. The trial court denied relief. The Supreme Court affirmed, holding (1) the only cognizable claims were the ineffective assistance of counsel claims that Appellant raised below and reasserted on appeal; and (2) the trial court did not clearly err when it found that Appellant had failed to demonstrate that he suffered prejudice as a result of his counsel's alleged errors. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis filed by Petitioner, holding that Petitioner failed to state sufficient facts to establish a violation of Brady v. Maryland, 373 U.S. 83 (1963).Petitioner was convicted of robbery, theft of property, and employment of a firearm to commit aggravated robbery. In his coram nobis petition, Petitioner alleged that exculpatory testimony of two witnesses was suppressed in violation of Brady. The Supreme Court denied the petition, holding that Petitioner did not state facts that established a Brady violation but, instead, alleged ineffective assistance of counsel claims, which are not cognizable in coram nobis proceedings. View "Talley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting summary judgment to Appellees and dismissing Appellant's civil rights claim, holding that the circuit court did not err in granting summary judgment in favor of Appellees.Appellant, an inmate in the Arkansas Department of Corrections (ADC), brought causes of action against Appellees, employees of the ADC, under 42 U.S.C. 1983, the Eighth Amendment, and Arkansas law. The circuit court granted summary judgment in favor of Appellees on the basis of qualified immunity. The Supreme Court reversed and remanded in part. On remand, the circuit court granted Appellees' motion for summary judgment, concluding that Appellees were entitled to qualified immunity. The Supreme Court affirmed, holding that Appellees, as state employees, were protected by qualified immunity. View "Early v. Crockett" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, aggravated robbery, and a firearm enhancement, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the circuit court erred in denying his motion to suppress his statements to police recorded in a police interrogation room and an alleged nonrecorded custodial statement made while police escorted him to a police car. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in rejecting Defendant's argument that the issuance of Miranda warnings was rendered ineffective; and (2) Defendant's remaining allegations of error were without merit. View "Pree v. State" on Justia Law