Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
State v. Thompson
After a jury trial, Defendant was found guilty of second-degree sexual assault and rape. The Supreme Court affirmed the convictions. Thereafter, Defendant filed original and amended petitions for postconviction relief pursuant to Ark. R. Crim. P. 37.1, asserting ineffective assistance of counsel. The trial court granted the original and amended petitions for postconviction relief, concluding that counsel provided ineffective assistance and that the court was unable to say that counsel’s failures did not affect the outcome of the sentencing phase. The Supreme Court reversed, holding that the trial court’s finding of prejudice was clearly erroneous. View "State v. Thompson" on Justia Law
Lane v. State
Appellant, a parolee, was charged as a habitual criminal offender with simultaneous possession of drugs and a firearm, possession of methamphetamine with intent to deliver, and possession of drug paraphernalia. Appellant filed a motion to suppress the evidence seized during his arrest on the basis that officers entered his hotel room without a warrant and without knocking and announcing their presence. The circuit court denied the motion. The Supreme Court affirmed, holding (1) the knock-and-announce rule applies to parolees, but the exclusionary rule is not the appropriate remedy; and (2) despite the knock-and-announce violation, the evidence seized from Appellant should not have been suppressed. View "Lane v. State" on Justia Law
Beverage v. State
Defendant pleaded guilty to charges from several different cases, including first-degree murder, aggravated robbery, and first-degree escape. Defendant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel due to his counsel’s failure to request a competency hearing. The circuit court denied relief, concluding that trial counsel made a reasonable decision not to pursue the competency question further, and that decision did not prejudice Defendant. The Supreme Court affirmed, holding that Defendant did not satisfy the Strickland v. Washington test for ineffective-assistance-of-counsel claims under Rule 37.1. View "Beverage v. State" on Justia Law
Liggins v. State
After a jury trial, Defendant was convicted of first-degree murder and first-degree battery. Defendant was sentenced to an aggregate sentence of sixty-five years’ imprisonment. The court of appeals affirmed. Thereafter, Defendant filed a petition for postconviction relief pursuant to Ark. R. Civ. P. 37.1, in which he asserted numerous claims of ineffective assistance of counsel. The circuit court denied the petition after a hearing. The Supreme Court affirmed, holding that the circuit court did not err in denying Defendant’s claims that his appellate counsel provided ineffective assistance and that his trial counsel provided ineffective assistance. View "Liggins v. State" on Justia Law
Smith v. Pavan
Appellees, three married female couples, filed suit against Appellant, the director of the Arkansas Department of Health, seeking a declaration that the refusal to issue birth certificates with the names of both spouses of the birth certificates of their respective minor children violated their equal protection and due process rights. Appellees also sought an order requiring Appellant to issue corrected birth certificates. The circuit court ordered Appellant to issue three amended birth certificates naming both spouses. The Supreme Court reversed, holding (1) the circuit court erred in finding that the case was controlled by Smith v. Wright; and (2) the circuit court erred in finding that Ark. Code Ann. 20-18-401(e) and (f) and Ark. Code Ann. 20-18-406(a)(2) facially violated Appellees’ rights to due process and equal protection. View "Smith v. Pavan" on Justia Law
Turner v. State
Appellant was found guilty of aggravated robbery and theft of property with a firearm enhancement. Appellant was sentenced to life imprisonment. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that he was denied effective assistance of counsel and that he was denied a fair and impartial trial because the jury and victims were all white and the trial judge was aggravated with him. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court’s decision to deny the requested relief was not clearly erroneous. View "Turner v. State" on Justia Law
Smith v. State
In 2013, Appellant was convicted of raping a young girl and sentenced to forty years’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The trial court denied relief, concluding that counsel’s performance was not ineffective. The Supreme Court affirmed, holding that the circuit court did not err in finding (1) counsel was not ineffective for failing to object to hearsay testimony from witnesses; (2) counsel was not ineffective for failing to object to a sleeping juror; and (3) counsel was not ineffective for failing to call into question the credibility of the alleged victims. View "Smith v. State" on Justia Law
Millsap v. Kelley
Appellant pleaded guilty to capital murder, terroristic threatening, and second-degree battery. Appellant was sentenced to life imprisonment without the possibility of parole and two six-year terms of imprisonment to run concurrently with the life sentence. The Supreme Court affirmed. Appellant later filed a pro se petition for declaratory judgment and writ of mandamus challenging the constitutionality of his sentence to life without parole. The circuit court dismissed the petition with prejudice. The Supreme Court dismissed Appellant’s appeal, holding that Appellant failed to state a basis for declaratory relief and provided no basis for a writ of mandamus to issue. View "Millsap v. Kelley" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Dennis v. State
After a jury trial, Defendant was found guilty of capital murder, two counts of aggravated robbery, and two counts of kidnapping. Defendant elected to forgo sentencing by the jury. The State did not seek the death penalty for the capital murder conviction, for which Defendant automatically received a life sentence without parole. The circuit court sentenced Defendant as a habitual offender to concurrent terms of life imprisonment for the remaining offenses. The Supreme Court affirmed, holding that, by making certain rulings, the circuit court did not deny Defendant (1) the right to self-representation, (2) the right of confrontation, or (3) the right to the assistance of counsel. View "Dennis v. State" on Justia Law
Ross v. Martin
This was the second part of a bifurcated case concerning a proposed amendment to the state Constitution referred to as “An Amendment to Limit Attorney Contingency Fees and Non-Economic Damages in Medical Lawsuits.” Petitioners filed an original action in the Supreme Court for an order to invalidate the proposed amendment either by striking it from the ballot or by enjoining the counting of the votes. The petition asserted three bases for relief. The Supreme Court granted a motion to bifurcate the case and appointed a special master to make findings on counts I and II. This opinion addressed counts I and II. Ultimately, having already granted the petition based on the grounds asserted in count III, the Court declared its consideration of counts I and II moot. View "Ross v. Martin" on Justia Law
Posted in:
Constitutional Law