Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Chambliss v. State
After a jury trial, Appellant was found guilty of two counts each of aggravated robbery and theft of property. The charges arose from the aggravated robbery of two different banks, two days apart, and the charges were joined for trial. Appellant was sentenced to an aggregate term of 672 months imprisonment. After the judgment was affirmed, Appellant filed a pro se petition for postconviction relief, which the trial court denied. Appellant later filed a pro se petition for writ of habeas corpus, raising claims of trial error and insufficiency of the evidence. The Supreme Court denied relief because Appellant failed to raise a claim within the purview of a habeas action and thus failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Chambliss v. State" on Justia Law
Henderson v. State
In 1986, Appellant was found guilty of murder in the first degree and battery in the first degree and sentenced to life imprisonment. In 2013, Appellant filed in the circuit court in the county where he was in custody a pro se petition for writ of error coram nobis and for writ of habeas corpus, contending, among other claims, that he was actually innocent of the offenses. The circuit court dismissed the petition. The Supreme Court dismissed Appellant’s appeal and mooted his motion for appointment of counsel, holding (1) the circuit court where Appellant was incarcerated did not have authority to consider Appellant’s writ of error coram nobis; and (2) Appellant did not state a ground on which the writ of habeas corpus could issue. View "Henderson v. State" on Justia Law
Giles v. Ozark Mountain Reg’l Pub. Water Auth.
Ozark Mountain Regional Public Water Authority filed a complaint for condemnation and declaration of taking, seeking to take property owned by Appellants. That same day, Ozark deposited $66,986, the fair-market-appraisal amount of the property, with the clerk of court. Appellants challenged the amount deposited, claiming it was not sufficient compensation. After a trial, the jury awarded Appellants $341,500 in compensation for the property. Thereafter, Appellants filed a motion for attorney’s fees pursuant to Ark. Code Ann. 18-15-605(b). The circuit court denied the motion, finding that section 18-15-605(b) was not applicable to Appellants’ case. The Supreme Court affirmed, holding that the circuit court did not err in finding that section 18-15-605(b) was not applicable to Appellants’ case and in thereby denying Appellants’ motion for attorney’s fees.
View "Giles v. Ozark Mountain Reg'l Pub. Water Auth." on Justia Law
Conley v. State
After a jury trial, Appellant was found guilty of delivery of crack cocaine, possession of drug paraphernalia, and possession of marijuana. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief, asserting that his trial counsel provided ineffective assistance. The circuit court denied the petition after a hearing. The Supreme Court affirmed in part and reversed in part, holding that Appellant’s counsel (1) did not render ineffective assistance by failing to produce testimony that was promised on opening statement; but (2) provided ineffective assistance by neglecting to make proper motions for directed verdict. Remanded with directions to dismiss the charges for possession of a controlled substance and possession of drug paraphernalia. View "Conley v. State" on Justia Law
Barber v. State
Appellant entered a negotiated plea of guilty to murder in the first degree and was sentenced 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 was ineffective for, among other things, not advising him that he would not be eligible for parole until he had served seventy percent of his sentence. The trial court denied Appellant’s petition after an evidentiary hearing. The Supreme Court dismissed Appellant’s appeal and mooted the motion Appellant filed asking for counsel to be appointed to represent him, holding that the trial court did not err in denying relief on Appellant’s claims. View "Barber v. State" on Justia Law
Breeden v. State
After a jury trial, Appellant was found guilty of one count of rape of his biological daughter and sentenced to life imprisonment. The Supreme Court affirmed on appeal. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was entitled to relief based on ineffective assistance of counsel and related trial errors. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding the record did not support the allegations, the allegations were without merit or conclusory, and Appellant was otherwise not entitled to relief on his claims. View "Breeden v. State" on Justia Law
Mathis v. State
After a jury trial, Appellant was found guilty of simultaneous possession of drugs and firearms, possession of a controlled substance, and maintaining a drug premises. After his convictions were affirmed on direct appeal, Appellant filed a pro se petition for postconviction relief, alleging that he was denied due process of law and that he had been denied effective assistance of counsel. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant failed to establish that he received ineffective assistance of counsel; and (2) Appellant was not entitled to relief on the remainder of his claims. View "Mathis v. State" on Justia Law
Hopkins v. City of Brinkley
Jon Hopkins submitted multiple requests to Brinkley Water & Sewer Department (“BW&S”) for the home address and payment history of Kathryn Harris, a municipal-utility ratepayer and resident of the City of Brinkley. BW&S provided a redacted history of Harris’s account history but did not disclose her home address. The circuit court found that BW&S was not required to provide Hopkins with Harris’s home address, a “public record” as defined by the Freedom of Information Act (FOIA). The Supreme Court reversed and remanded, holding that the circuit court erred in finding that the ratepayer’s home address was exempt from disclosure, as (1) the Federal Trade Commission’s Red Flags Rule does not preempt the FOIA’s disclosure requirements; (2) BW&S failed to offer proof that any customer’s home address qualifies as a “personal matter” and thus was “constitutionally protectable” under McCambridge v. City of Little Rock; and (3) Harris’s home address was available for inspection by Hopkins, irrespective of his purpose in seeking access. View "Hopkins v. City of Brinkley" on Justia Law
GSS, LLC v. Centerpoint Energy Gas Transmission Co.
CenterPoint Energy Gas Transmission Co., a gas pipeline company that has the power of eminent domain, filed a petition to condemn an easement on property owned by GSS, LLC. The circuit court entered an order of possession, and, after a trial, awarded GSS $64,000 as just compensation. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in excluding evidence of value of a contiguous parcel of land from a separate case; (2) did not err in granting summary judgment in favor of CenterPoint on GSS’s counterclaims; and (3) did not err in granting summary judgment to CenterPoint. View "GSS, LLC v. Centerpoint Energy Gas Transmission Co." on Justia Law
Thomas v. State
After a jury trial, Appellant was convicted of two counts of capital murder and sentenced to death. Appellant’s sentence and conviction were affirmed on appeal. Appellant subsequently filed an Ark. R. Crim. P. 37.5 petition, asserting that his trial counsel provided ineffective assistance. After a hearing, the circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant’s claim that he received ineffective assistance of counsel on the grounds that his counsel did not object to a change of venue and because his counsel failed to secure and present the testimony of one of the investigating officers of the murders. View "Thomas v. State" on Justia Law