Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional 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.”
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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
Posted in:
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