Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Decay v. State
Appellant was convicted of two counts of capital murder and sentenced to death. The Supreme Court affirmed the convictions and sentence on appeal. Appellant subsequently filed a Rule 37.5 petition for postconviction relief, asserting that he was denied effective assistance of counsel in several respects. The circuit court denied and dismissed Appellant’s petition. The Supreme Court affirmed, holding that Appellant failed to show that his counsel’s performance was deficient under the two-prong standard set forth in Strickland v. Washington, and therefore, the circuit court did not err in denying Appellant’s petition.View "Decay v. State" on Justia Law
Chance v. Hobbs
Appellant was convicted of rape and incest. Ten years later, Appellant filed a petition for writ of habeas corpus, alleging (1) he never gave permission to “dismiss or waive” a jury trial; (2) Ark. R. Crim. P. 24.3-24.7 were not adhered to; and (3) the public defenders allowed perjured testimony to be entered and not challenged. The circuit court denied the habeas petition. Appellant lodged an appeal of that order and filed a motion for extension of time to file a reply brief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Petitioner failed to raise a claim within the purview of a habeas action and therefore failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue.View "Chance v. Hobbs" on Justia Law
Carroll v. Hobbs
Appellant entered a plea of guilty to rape and was sentenced as a habitual offender to 720 months’ imprisonment. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the Arkansas Department of Correction (ADC), arguing that the Director denied him due process of law by applying Ark. Code Ann. 16-93-611 and 5-4-501(c) to his case. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not demonstrate that both the statutory provisions requiring him to be fifty-five years of age and also to have served seventy percent of his sentence should not have been applied to his parole or transfer eligibility, or that he was entitled to any relief by means of a declaratory judgment or writ of mandamus.
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Bowerman v. Takeda Pharms. U.S.A.
Petitioner, as a representative of a constitutional class-action of citizen-taxpayers of the State, brought a case against Takeda Pharmaceuticals U.S.A. and related companies (collectively, Respondents), alleging that an illegal exaction had taken place. Respondents were engaged in the business of developing, manufacturing, and selling “Actos” for the treatment of Type II diabetes mellitus. Actos was prescribed by physicians in Arkansas, and certain amounts of the payments for these drugs were reimbursed by the state. Respondents filed a motion to dismiss, alleging that Petitioner failed to state a claim upon which relief could be granted. The federal district court certified questions of law to the Supreme Court regarding the issues presented in this case. The Supreme Court answered that Ark. Const. art. 16, 13 does not provide Petitioner with a claim for illegal exaction under the facts and circumstances of this case.View "Bowerman v. Takeda Pharms. U.S.A." on Justia Law
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Constitutional Law, Health Care Law
Atkins v. State
After a jury trial, Appellant was found guilty of first-degree battery, being a felon in possession of a firearm, and use of a firearm in commission of a felony. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. Appellant then filed a pro se petition to correct an illegal sentence, raising several allegations of error. The trial court dismissed the petition. The Supreme Court affirmed, holding that Appellant’s claims were either not within the purview of his petition to correct an illegal sentence or without merit.View "Atkins v. State" on Justia Law
Schrader v. State
Appellant entered a plea of guilty to three counts of rape and was sentenced to three consecutive terms of life imprisonment. Appellant subsequently filed in the trial court a petition for writ of error coram nobis, arguing that the writ should issue on the ground that he was not afforded effective assistance of counsel with respect to a plea bargain that was offered to him. The trial court denied the petition. The Supreme Court affirmed, holding that the claims in the petition were clearly outside the purview of a coram-nobis proceeding, and therefore, Appellant failed to establish that the writ should issue.View "Schrader v. State" on Justia Law
Pennington v. Hobbs
In 1978, Appellant pleaded guilty to first-degree murder, four counts of aggravated robbery, and first-degree battery. Appellant received concurrent sentences of life imprisonment for the charge of murder and each of the aggravated-robbery charges. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging, among other claims, that his sentence to life imprisonment without the possibility of parole for crimes he committed when he was a minor was unconstitutional. The Supreme Court dismissed the appeal and declared moot or denied the motions filed pertaining to the appeal, holding (1) because Appellant was not subjected to a mandatory sentence of life without parole, Appellant’s sentences were not illegal under Miller v. Alabama; and (2) the remaining assertions raised by Appellant were not cognizable in a habeas proceeding.View "Pennington v. Hobbs" on Justia Law
Ingram v. State
After a jury trial, Appellant was found guilty of capital murder for the death of his twenty-three-month-old son. Appellant was sentenced to life imprisonment without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed the appeal and denied and mooted the motions pertaining to the appeal, holding that the trial court did not clearly err in holding that counsel’s performance was not ineffective.View "Ingram v. State" on Justia Law
Gardner v. Hobbs
After a jury trial, Appellant was found guilty of capital murder and aggravated robbery and was sentenced to an aggregate term of life imprisonment without parole. Appellant later filed a pro se petition for writ of habeas corpus, bringing claims pertaining to double jeopardy, sufficiency of the evidence, ineffective assistance of counsel, and his actual innocence. The circuit court denied the habeas petition. Appellant appealed and also filed a motion for appointment of counsel to represent him on appeal. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion for appointment of counsel, holding that because Appellant did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, the circuit court did not err when it dismissed the petition.
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Chunestudy v. State
Appellant was found guilty of rape and sentenced to life 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. After a hearing, the trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in declining to grant relief under Rule 37.1 under the circumstances of this case because, while counsel erred in some respects, Appellant did not demonstrate that counsel’s deficient performance so prejudiced Appellant’s defense that he was deprived of a fair trial.View "Chunestudy v. State" on Justia Law