Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Nalls v. State
After a jury trial, Defendant was convicted of one count of delivery of cocaine. Defendant was sentenced as a habitual offender to 480 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel provided ineffective assistance. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the circuit court did not err in denying the petition without a hearing; and (2) based on the standard established in Strickland v. Washington, the circuit court did not err in finding that counsel’s performance was not constitutionally defective. View "Nalls v. State" on Justia Law
Ark. State Claims Comm’n v. Duit Constr. Co.
Appellee, a construction company, filed a complaint for declaratory judgment against Appellants, the Arkansas State Claims Commission, the General Assembly’s Claims Review Subcommittee, the General Assembly’s Joint Budget Committee, the Arkansas State Highway Commission, and the Arkansas State Highway and Transportation Department. The circuit court granted in part and denied in part Appellants’ motion to dismiss. The Supreme Court reversed and remanded on direct appeal and granted Appellants’ motion to dismiss the cross-appeal, holding (1) Appellee’s equal-protection claim was barred by sovereign immunity; and (2) the Court lacked jurisdiction over Appellee’s cross-appeal. View "Ark. State Claims Comm'n v. Duit Constr. Co." on Justia Law
Martin v. Kohls
After the General Assembly passed Act 595 of 2013, Appellees, registered voters in Pulaski County, filed a complaint for injunctive and declaratory relief, arguing that sections of the Act that allegedly placed an additional qualification and impairment on Arkansas residents before they could exercise their right to vote violated the Arkansas Constitution. The circuit court concluded that Act 595 was unconstitutional, enjoined and restrained Appellants, the Secretary of State and the Commissioners of the State Board of Election Commissioners, from enforcing any proof-of-identity provisions of the Act and from enforcing their rules promulgated as a result of the Act, and granted a preliminary injunction against Appellants from enforcing Act 595’s proof-of-identity requirements in favor of Appellants. The Supreme Court affirmed the circuit court’s ruling that Act 595 was unconstitutional on its face, holding that the Act’s requiring proof of identity was unconstitutional on its face and imposed a requirement that fell outside the ambit of Ark. Const. art. III, 1. View "Martin v. Kohls" on Justia Law
Stewart v. State
After a jury trial, Appellant was found guilty of the rape of twenty-three-year-old J.H., who was incapable of consent by virtue of her mental age of six or seven years. Appellant was sentenced to 840 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel at trial. The trial court denied the petition after a hearing. The Supreme Court affirmed, holding that Appellant failed to establish that his counsel’s performance was deficient in any respect. View "Stewart v. State" on Justia Law
McMiller v. State
After a jury trial, Appellant was convicted of capital murder, aggravated residential burglary, kidnapping, and rape. Appellant was sentenced to life without parole for the capital murder conviction. On appeal, Appellant argued that the circuit court erred in denying his objection to the State’s use of peremptory challenges in violation of Batson v. Kentucky. Specifically, Appellant claimed that there was purposeful discrimination in that six of the eight strikes used by the State were strikes of black potential jurors, which resulted in Appellant, an African American, being tried by an all-white jury. The Supreme Court affirmed, holding that the circuit court did not clearly err in denying Appellant’s Batson challenge. View "McMiller v. State" on Justia Law
Holliday v. Hobbs
Appellant was found guilty of sexual assault in the second degree and rape and sentenced to an aggregate term of 720 months’ imprisonment. Appellant later filed a pro se petition for writ of habeas corpus, alleging that the evidence was insufficient to sustain the jury’s finding of guilt, that his conviction was the result of ineffective assistance from his attorney, and that there were a number of errors in his trial. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s petition did not make the showing required for issuance of the writ, and therefore, the circuit court did not err when it dismissed the petition.View "Holliday v. Hobbs" on Justia Law
Winters v. State
Appellant was convicted of two counts of capital murder and two counts of aggravated robbery. Appellant was sentenced to two sentences of life imprisonment without parole for the capital murders and two sentences of life imprisonment for the aggravated robberies, to be served consecutively. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was not afforded effective assistance of trial counsel. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and declared the motion filed in relation to the appeal moot, holding that Appellant failed to make even one meritorious claim of ineffective assistance of counsel.View "Winters v. State" on Justia Law
Sales v. State
Appellant was convicted of capital murder and aggravated robbery. Appellant was sentenced to death and life imprisonment, respectively. The Supreme Court affirmed on appeal. Appellant then filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, alleging that his trial counsel were ineffective during the sentencing phase of his capital-murder trial and during opening statements. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court correctly concluded that Appellant was not entitled to relief because he could not demonstrate that he was prejudiced as required by the second prong of Strickland v. Washington at either phase of his trial.View "Sales v. State" on Justia Law
Quezada v. Hobbs
Appellant pleaded guilty to one count of delivery of a controlled substance and two counts of possession of a controlled substance with intent to deliver. Appellant was sentenced to a total of 300 months’ imprisonment with an additional 180 months’ suspended imposition of sentence for each count. Appellant later filed a pro se petition for writ of habeas corpus, claiming that the proscription against double jeopardy was violated in his case because he was convicted of both delivery of a controlled substance and possession of the controlled substance with intent to deliver. The circuit court denied habeas relief. The Supreme Court affirmed, holding that Appellant did not meet his burden of demonstrating that the face of the judgment demonstrated that the judgment was invalid.View "Quezada v. Hobbs" on Justia Law
Jasper Sch. Dist. No. 1 v. Cooper
Anita Cooper, who was employed as principal of the Oark, Arkansas schools, was removed from her duties as principal. The Superintendent of the Jasper School District No. 1 of Newton County listed nine reasons as bases for the termination. The District’s Board of Directors then terminated Cooper’s employment. The circuit court reversed the Board’s decision, reinstated Cooper to her position, and awarded Cooper $64,998 in damages. The Superintendent and District appealed. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendants failed to comply with the Teacher Fair Dismissal Act; (2) the circuit court did not err in concluding that the contract in the case at bar created a property right in Cooper’s position as principal of the Oark schools; and (3) the circuit court’s award to Cooper was neither excessive nor amounted to an award of “double retirement.”
View "Jasper Sch. Dist. No. 1 v. Cooper" on Justia Law