Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
McDaniels v. State
Petitioner was convicted of two counts of rape and sentenced to an aggregate sentence of 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel at trial. The Supreme Court denied the petition, holding that Petitioner's allegation was outside the purview of a coram-nobis proceeding, and to the extent that Petitioner may have intended his claims to be an attack on the sufficiency of the evidence or the credibility of witnesses, such issues were also not cognizable in coram-nobis proceedings. View "McDaniels v. State" on Justia Law
Khabir v. Hobbs
Appellant was convicted of delivery of a controlled substance and sentenced to an enhanced sentence of forty years' imprisonment and a fine. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief and, later, a motion to correct an illegal sentence. Both requests were denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus raising double-jeopardy claims. The circuit court denied the petition. Appellant appealed and filed with the Supreme Court a motion for extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant's claims were not cognizable in a petition for habeas corpus. View "Khabir v. Hobbs" on Justia Law
State v. Myers
Appellee was charged with felony possession of drug paraphernalia and misdemeanor possession of a controlled substance. The charges stemmed from a probationary search of the bedroom he rented and sometimes shared with his girlfriend, a probationer. Appellee moved to suppress the evidence on the basis that the warrantless search of his bedroom was conducted without his consent, without probable cause, and without exigent circumstances. After a hearing, the circuit court ruled that the State failed to prove the reasonableness of the warrantless, probationary search as to Appellee because Appellee did not expressly consent to the search. The Supreme Court dismissed the State's appeal, holding that resolution of this case turned on application of its unique facts to the law, and therefore, the correct and uniform administration of the criminal law did not require the Court's review. View "State v. Myers" on Justia Law
State v. Jones
Appellee's husband, a parolee, resided with Appellee. After a parole agent determined that a parole search of the residence was warranted, the parole officer and other police officers searched the residence. Appellee was subsequently charged with possession of methamphetamine and possession of drug paraphernalia. Prior to trial, Appellee filed a motion to suppress, alleging (1) police officers conducted the search without a warrant, without consent, and without reasonable cause; and (2) her arrest exceeded the authority of the parole officer. The circuit court granted Appellee's motion to suppress, ruling that reasonable grounds for a parole search must exist and more-than-minimal police involvement was necessary in the parole search at issue. The Supreme Court dismissed for lack of a proper State appeal where (1) the State's appeal involved only the application of a rule or statute; and (2) because the trial court acted on a mixed question of law and fact, the matter was not appealable by the State. View "State v. Jones" on Justia Law
Sims v. State
After a jury trial, Petitioner was found guilty of first-degree murder and sentenced to 600 months' imprisonment. The judgment was affirmed on direct appeal. Petitioner then sought postconviction relief in the trial court. The petition was dismissed on the ground it was not timely filed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the evidence was not sufficient to sustain the judgment-and-commitment order. The Supreme Court denied the petition, holding that Petitioner's claim was not cognizable in a coram-nobis proceeding. View "Sims v. State" on Justia Law
McCutchen v. City of Fort Smith
This case involved provisions of the Arkansas Freedom of Information Act (FOIA). The circuit court dismissed Appellant's complaint against Appellees, the city, the city administrator, and members of the board of directors, contending that the administrator violated the open-meetings provision of the FOIA when he presented to individual board members, in advance of a study session, a memorandum expressing his opinion on a proposed ordinance that might come before the board. The circuit court found in favor of Appellees. The Supreme Court (1) affirmed the circuit court's conclusion that the administrator did not violate the open-meetings provision of the FOIA; and (2) reversed the circuit court's findings of fact and conclusions of law relating to its determination that the FOIA's open-meetings provision and criminal provision were unconstitutional. In so holding, the Court declined to grant Appellees' request to overrule Harris v. City of Fort Smith, in which the Court construed the open-meetings provision of the FOIA to give effect to the intent of the legislature that public business be performed in an open and public manner. View "McCutchen v. City of Fort Smith" on Justia Law
Stewart v. State
Appellant was convicted by a circuit court jury of one count of rape and one count of second-degree sexual assault. Appellant was sentenced to life imprisonment, an additional eighteen years, and $10,000 fine. Appellant appealed, alleging that the circuit court abused its discretion by overruling his objections to the prosecution's closing argument during the guilt phase of his trial. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling Appellant's objections to the prosecution's closing argument, as the prosecution's closing argument did not constitute error and was in response to the credibility challenges made to its witnesses. View "Stewart v. State" on Justia Law
Girley v. Hobbs
Appellant was found guilty of rape by a jury in the circuit court and was sentenced to 300 months' imprisonment. The court of appeals affirmed as modified. Appellant's subsequent petition for postconviction relief was denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus, contending (1) he had new scientific evidence to prove his innocence, (2) his trial attorney was ineffective, (3) he was denied due process of law by trial errors and the failure of the prosecution to comply with discovery requests and the reliance by the prosecution on perjured testimony to gain the conviction, and (4) the evidence was insufficient to sustain the judgment. The circuit court dismissed the petition. The Supreme Court dismissed the appeal and declared the motion related to the appeal moot, holding that because Appellant failed to state cognizable claims, he did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue.
View "Girley v. Hobbs" on Justia Law
Watson v. State
Appellant appealed an order of the circuit court convicting him of capital murder and sentencing him to life imprisonment without parole. For reversal, Appellant argued that the circuit court erred in denying his motion to suppress his statement given to police. Specifically, Appellant contended that his statement should be suppressed because he invoked his Fifth Amendment right to counsel during his interview with police. The Supreme Court affirmed, holding that Appellant's argument failed because his statement was never introduced into evidence at trial, and therefore, Appellant failed to demonstrate how he was prejudiced by the non-use of those statements. View "Watson v. State" on Justia Law
McWilliams v. Pope County Bd. of Equalization
This was an appeal from a circuit court judgment affirming the classification of real property for tax purposes. The Supreme Court affirmed, holding (1) the circuit court correctly found that the Arkansas Constitution and the Assessment Coordination Rules and Regulations allowed the land at issue to be classified as residential and not timber land; (2) ad hoc requirements were not imposed only on Appellants by Appellee Pope County Board of Equalization (BOE); (3) Appellants failed to demonstrate that they were similarly situated to any other taxpayer or landowner within the city limits, and therefore, Appellants' equal-protection claim that the circuit court erred in denying Appellants' petition without considering similarly situated property owners with similar property classified as timber and pasture within city limits was without merit; and (4) the circuit court did not abuse its discretion in allowing a site visit by BOE's expert witness between the first day of trial and the second day of trial. View "McWilliams v. Pope County Bd. of Equalization" on Justia Law