Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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After a jury trial, Appellants Michael Myers and Scott Hall were convicted of several drug-related crimes. Appellants' convictions were affirmed by the court of appeals. Appellants subsequently filed petitions for postconviction relief, alleging ineffective assistance of counsel. The trial court entered orders denying postconviction relief as to both Appellants. The Supreme Court affirmed the denial of postconviction relief, holding that Appellants failed to meet their burden under Washington v. Strickland by failing to demonstrate that their counsel was deficient or that, if counsel was deficient, there was a reasonable probability that, but for counsel's errors, the fact-finder would have had a reasonable doubt respecting guilt. View "Myers v. State" on Justia Law

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Appellant Corey Lambert was convicted on charges of attempted murder in the first degree, aggravated robbery, and theft of property. The court of appeals affirmed Appellant's convictions. Appellant subsequently filed a petition for postconviction relief, stating four grounds for relief in his petition. All of Appellant's stated grounds alleged ineffective assistance of counsel in connection with the State's failure to introduce certain physical evidence during Appellant's jury trial. The trial court denied the petition. Appellant appealed, and before the Supreme Court was a motion Appellant filed related to his appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant's petition was clearly without merit, as Appellant failed to demonstrate that counsel might have raised a successful challenge to the disputed evidence, and none of Appellant's grounds for relief demonstrated prejudice. View "Lambert v. State" on Justia Law

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Appellant Carlos Keck was convicted of rape and sentenced to twenty-five years' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, asserting that his trial counsel was ineffective for not objecting or making an attempt to limit expert testimony that Appellant alleged improperly bolstered the victim's testimony. The trial court denied the petition. The Supreme Court affirmed, holding that trial counsel's performance did not fall below an objective standard of reasonableness under the first prong of Washington v. Strickland, and therefore, the trial court did not err in finding that counsel's performance was not ineffective. View "Keck v. State" on Justia Law

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Appellant Phillip Harrison was convicted of two counts of theft of property. Appellant subsequently filed a pro se petition for postconviction relief. The trial court denied the petition, finding that it was not timely filed, but provided a ruling on two issues raised in the petition, despite that finding. Appellant appealed, and before the Supreme Court were several motions related to the appeal. The Court dismissed the appeal and declared the motions moot, holding (1) the trial court erred in reaching issues not related to whether the petition met the procedural requisites of the Court's rules; and (2) the trial court correctly denied relief on the petition because no relief could be granted on an untimely petition. View "Harrison v. State" on Justia Law

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Appellant Damont Ewells, who was incarcerated, filed a civil complaint against Appellees, three law enforcement officers, seeking compensatory and punitive damages and injunctive relief. In his complaint, Appellant alleged that Appellees violated his constitutional rights, specifically claiming due process and excessive force violations. The circuit court granted Appellees' motion for summary judgment and dismissed Appellant's complaint with prejudice. The Supreme Court affirmed, holding that Appellant, as the opposing party, failed to meet proof with proof and to demonstrate the existence of a genuine issue of material fact, and therefore, the circuit court properly granted summary judgment in favor of Appellees. View "Ewells v. Constant" on Justia Law

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William Eubanks was convicted of rape and sentenced to life imprisonment. Eubanks subsequently filed a petition for postconviction relief, asserting that his trial counsel was ineffective for failing to challenge his prosecution based on speedy trial and for failing to mount a constitutional challenge to the pedophile exception recognized by the Supreme Court under Ark. R. Evid. 404(b). The Court affirmed, holding (1) there was no violation of Eubanks' right to a speedy trial, and therefore, Eubanks' trial counsel was not ineffective for failure to assert a violation of Eubanks' right to a speedy trial; and (2) the failure of counsel to make a constitutional challenge to the established evidentiary rule of allowing for a pedophile exception in admission of evidence did not constitute an error so serious to rise to the level of ineffective assistance of counsel. View "Eubanks v. State" on Justia Law

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After a jury trial, Appellant Lesa Menne was found guilty of possession of drug paraphernalia with the intent to use, and possession of marijuana. On appeal, Menne challenged the circuit court's denial of her motion to suppress evidence recovered in a search of her vehicle after she was stopped by a law enforcement officer for a traffic violation. The Supreme Court affirmed the circuit court's ruling, holding that the circuit court correctly found that a number of factors gave the officer a reasonable suspicion during the course of the traffic stop that Menne was committing, had committed, or was about it commit a crime involving danger to persons or property, and that reasonable suspicion was a sufficient basis to detain Menne further. View "Menne v. State" on Justia Law

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A jury convicted Appellants Angel Romero and Conrado Cordona-Duarte of possession of cocaine with intent to deliver and possession of drug paraphernalia. The court of appeals affirmed Appellants' felony drug convictions, as well as the convictions of their co-defendant, Luis Camacho-Mendoza. The court of appeals issued the mandate for the appeal, but the clerk's certificate named only Camacho-Mendoza as appellant. Appellants then filed an Ark. R. Crim. P. 37.1 petition, which the circuit court denied as prematurely filed because no mandate listing Appellants had been filed with the county circuit clerk. The Supreme Court reversed, holding that although the trial court may not have had the correct information available to it upon which to make a decision at the time it issued the order, Appellants' petition was timely filed. Remanded. View "Romero v. State" on Justia Law

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Appellant David Paschal was convicted of four counts of second-degree sexual assault and one count of witness bribery. The Supreme Court affirmed in part, reversed and remanded in part, and reversed and dismissed in part, holding that the circuit court (1) did not err in denying Appellant's motion for directed verdict on the witness-bribery charge; and (2) erred in finding the sexual-degree sexual-assault statute constitutional as it was applied to Appellant because the statute, as applied in this case, infringed on Appellant's fundamental right to engage in private, consensual, noncommercial acts of sexual intimacy with an adult and was not the least restrictive method available for the promotion of a state interest. View "Paschal v. State" on Justia Law

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Petitioner Robert Hoover was convicted of capital murder and aggravated robbery and was sentenced to two life sentences. Hoover subsequently petitioned the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the petition, holding that Petitioner failed to meet his burden to show that the writ is warranted, as only one of Petitioner's three claims was of the ilk that may be cognizable in proceedings for the writ, and that claim was without merit because the asserted error did not raise a reasonable probability that the judgment of conviction would not have been rendered, or would have been prevented, if the facts Petitioner alleged were withheld had been available at trial. View "Hoover v. State" on Justia Law