Justia Arkansas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the Arkansas Department of Correction (ADC) denying Appellant's petition to proceed in forma pauperis in a civil action requesting judicial review, holding that Appellant failed sufficiently to raise a constitutional question.In his civil action, Appellant asserted that prison officials initiated and conducted disciplinary proceedings against him in violation of his constitutional rights. The circuit court concluded that Appellant failed to state a colorable cause of action and that ADC officials were entitled to sovereign immunity. The Supreme Court affirmed the circuit court's denial of Appellant's petition, holding that Appellant did not state sufficient allegations entitling him to judicial review of ADC's administrative procedures. View "Muntaqim v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for preliminary injunction, holding that the circuit court correctly concluded that Appellant failed to demonstrate a likelihood of success on the merits.Appellant was an inmate of the Arkansas Department of Correction (ADC) and a professed member of the Nation of Islam (NOI). Appellant filed the underlying suit against numerous ADC officials, alleging violations of the First Amendment and the federal Religious Land Use and Institutionalized Persons Act. Appellant moved for a preliminary junction against ADC's publications policy as applied to NOI material and against ADC's religious services policy so that he may lead NOI services in prison. The circuit court denied Appellant's motion for preliminary injunction, determining that Appellant failed to show irreparable harm and failed to demonstrate a likelihood of success on the merits. The Supreme Court affirmed, holding that the circuit court did not exceed its discretion in deciding not to issue a preliminary injunction. View "Muntaqim v. Lay" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying the motion to dismiss filed by Jimmy Banks, Warden of the Varner Unit of the Arkansas Department of Correction (ADC), as to Sharon Jones's complaint alleging that she had been terminated from her employment at the Varner Unit due to racial and gender discrimination, holding that Jones failed to state factual allegations that alleged a deprivation of any constitutional right.In her complaint, Jones, an African American woman, alleged that she was subjected to unlawful racial and gender discrimination because she was discharged under circumstances that similarly situated white or male employees were not. Banks filed a motion to dismiss based on constitutional sovereign immunity, qualified immunity, and statutory immunity. The circuit court denied the motion. The Supreme Court reversed, holding that Banks was entitled to qualified immunity under Jones's 42 U.S.C. 1983 claims and statutory immunity against her state law claims. View "Banks v. Jones" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that it was clear from the face of the petition that Appellant did not substantiate with facts a ground for relief in his Rule 37.1 petition.In his petition, Appellant alleged four of his claims of ineffective assistance of counsel. The trial court denied the petition. Appellant appealed and filed a motion for an extension of time to file a reply brief in the appeal. The Supreme Court (1) affirmed the denial of Appellant's postconviction petition, holding that Appellant failed to support the four allegations that he argued on appeal were wrongfully decided by the trial court with facts to demonstrate that he suffered actual prejudice by any of counsel's alleged errors; and (2) denied the motion for extension of brief time, holding that there was no good cause to delay action on the appeal by granting leave to file a reply brief. View "Maiden v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition for a writ of error coram nobis, which mooted Appellant's motion to file a belated brief-in-chief, holding that it was clear from the record that Appellant's allegations failed state a claim for coram nobis relief.In his petition, Appellant asserted that his guilty plea was not voluntarily or intelligently entered because his counsel led him to believe that his sentence would be life imprisonment, not life imprisonment without the possibility of parole. The Supreme Court dismissed the appeal, holding that Appellant did not allege that his guilty plea resulted from any form of physical or psychological duress as required for a writ of error coram nobis in this context. View "Wade v. State" on Justia Law