Justia Constitutional Law Opinion Summaries

Articles Posted in Arkansas Supreme Court
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The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's illegal exaction suit against the City of Blytheville and its Sewer Department (collectively, the City), holding that the circuit court properly granted summary judgment. In her complaint, Plaintiff claimed that a $5 fee for sewer system repairs and upgrades, imposed pursuant to a city ordinance, was a tax and constituted an illegal exaction in violation of article 16, section 13 of the Arkansas Constitution. The circuit court granted the City's motion for summary judgment and dismissed all of Plaintiff's claims with prejudice. The Supreme Court affirmed, holding that the circuit court correctly found that the fee was not a tax and, therefore, not an illegal exaction. View "Watson v. City of Blytheville" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, holding that there was no error in the circuit court's order denying Rule 37 relief. Defendant was convicted of capital murder and sentenced to death. Numerous proceedings followed. This appeal concerned Defendant's petition for postconviction relief. The circuit court entered an order denying Defendant relief on every claim. The Supreme Court affirmed, holding (1) there was no deficient performance by trial counsel under the Strickland standard; (2) the circuit court did not err in denying relief on the issue of Defendant's competency to stand trial; (3) Defendant's claim of juror misconduct was not cognizable in this postconviction proceeding; and (4) Defendant's remaining claims did not warrant reversal of his convictions. View "Roberts v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no basis for the writ. Appellant pleaded guilty to capital murder, attempted capital murder, and unlawful discharge of a firearm. Appellant later filed his petition for writ of habeas corpus, arguing that the State lacked jurisdiction to try him for the offenses because they were referred to as "international terrorism" committed by a "foreign terrorist organization" and that he was not afforded effective assistance of counsel. The Supreme Court affirmed, holding (1) the fact that Appellant's conduct could have been charged as a crime under a federal statute did not prohibit the State from trying him in state court; and (2) Appellant's claims of ineffective assistance of counsel were not cognizable as a ground for the writ. View "Muhammad v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court concluding that the district court's assessment of installment fees violated due process, holding that the circuit court correctly denied a directed verdict on the due process claim and that the City of Little Rock was properly held liable for the district court judge's actions. Plaintiff filed the underlying class action against the City alleging that the Little Rock District Court's installment fee practice constituted an illegal exaction and violated due process under the Arkansas Civil Rights Act, Ark. Code Ann. 16-123-101 to -108. The jury returned a verdict for Plaintiff, concluding that the installment fee practice violated due process and that the City was liable for the violation. The Supreme Court affirmed, holding (1) the circuit court did not err in holding that the installment fee practice violated due process; and (2) the due process violation arising from the district court judge's installment fee policy may be imputed to the City. View "City of Little Rock v. Nelson" on Justia Law

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The Supreme Court reversed the order of the circuit court denying the motion filed by the Arkansas Department of Human Services (DHS) to dismiss Plaintiffs' amended complaint alleging violations of the Arkansas Civil Rights Act, holding that sovereign immunity barred Plaintiffs' claims. In their complaint, Plaintiffs alleged, individually and on behalf of their three minor children, that the entrance of a DHS investigator and law enforcement into their children's private school for the purpose of investigating possible child maltreatment was illegal and unconstitutional. DHS filed a motion to dismiss, asserting sovereign immunity and other defenses. The circuit court denied the motion to dismiss. The Supreme Court reversed, holding that the circuit court erred in denying DHS's motion to dismiss based on sovereign immunity. View "Arkansas Department of Human Services v. Harris" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order awarding damages under the Arkansas Civil Rights Act to Alexander Apartments, LLC and certain tenants after determining that the City of Little Rock violated Appellees' due process rights under the Arkansas Constitution, holding that the circuit court correctly found that the City violated Appellees' due process rights but incorrectly awarded damages. On appeal, the City argued that it did not violate Alexander Apartments' or the tenants' due process rights under the Arkansas Constitution. The Supreme Court disagreed, holding (1) the circuit court was correct as a matter of law that the City violated Alexander Apartments' and the tenants' due process rights under the Arkansas Constitution; (2) substantial evidence supported the circuit court's award of damages to Alexander Apartments in the amount of $432,744.33; and (3) the circuit court erroneously considered events and circumstances that were unrelated to the City's due process violations in determining the tenants' damages awards. View "City of Little Rock v. Alexander Apartments, LLC" on Justia Law

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The Supreme Court affirmed in part and reversed in part the circuit court's order granting a motion to dismiss filed by the Arkansas Governor and Arkansas Livestock and Poultry Commission Deputy Director and dismissing Plaintiff's claims pursuant to the Arkansas Whistle-Blower Act, Ark. Code Ann. 21-1-601 et seq., as well as the state and federal constitutions, holding that sovereign immunity barred Plaintiff's claims against Defendants in their official capacities but was no defense to Plaintiff's claims against Defendants in their individual capacities. In his complaint, Plaintiff alleged that he was terminated because he refused to violate state policy. The circuit court dismissed all claims against Defendants solely on the basis of sovereign immunity. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) sovereign immunity precluded Plaintiff's official capacity claims; but (2) the circuit court erred when it found that sovereign immunity barred Plaintiff's claims against Defendants in their individual capacities. View "Harris v. Hutchison" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for post conviction relief pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court correctly denied Appellant's Rule 37.1 petition. Specifically, the Court held that the circuit court (1) did not clearly err by finding that trial counsel's failure to obtain a forensic evaluation prior to Appellant's pleading guilty was not ineffective assistance; (2) did not err in finding that trial counsel was not ineffective by failing to file any pretrial motions to suppress or motions in limine before permitting Appellant to enter his plea; and (3) did not apply the wrong legal standard in ruling on Appellant's petition. View "Roos v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for a writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the writ. Appellant pleaded guilty to aggravated robbery and was sentenced to a term of imprisonment. In his petition for a writ of error coram nobis Appellant alleged that his counsel did not fully explain his parole eligibility or the effect of his prior convictions, and therefore, he was coerced into pleading guilty. The circuit court denied the writ. The Supreme Court affirmed, holding that Appellant's allegations did not rise to the level of coercion sufficient to meet his burden of establishing grounds for the writ. View "Brown v. State" on Justia Law

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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally. Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law