Justia Constitutional Law Opinion Summaries

Petitioner Rolandis Chatmon was in jail at the time of his applications to the Arkansas Supreme Court for a writ of coram nobis. He was incarcerated on three counts of aggravated robbery and one count of theft of property. He was sentenced as a habitual offender, with a firearm enhancement, to a term of three life sentences plus 360 months’ imprisonment. His convictions and sentences were affirmed on direct appeal. He filed a second pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, and alternatively, for a writ of certiorari. Attached to the petition were: a letter of suspension and removal from office issued to Judge Michael Maggio, the trial judge in his aggravated robbery trial; a document reflecting that Chatmon’s case was transferred to Maggio’s court; Chatmon’s pro se motion for appointment of counsel filed in October 2012; and a letter from the Arkansas Public Defender Commission sent to Chatmon addressing complaints about his trial counsel. Chatmon contended that these documents, plus alleged comments the judge made with regard to Chatmon, reflected the trial judge's bias toward criminal defendants. Chatmon further asserted that this bias was the source of Maggio’s refusal to grant a request for a continuance so that a material witness and others could have been called. The Supreme Court had held previously that it would not exercise its discretion to permit a successive application for a writ of error coram nobis if the petitioner was abusing the writ by alleging the same grounds without additional facts sufficient to provide grounds for the writ. Furthermore, the Court found that with regard to certiorari relief, Chatmon failed to demonstrate that there was no other remedy to redress his contentions that he was unfairly denied a continuance and the appointment of other counsel. Accordingly, the petition for a writ of coram nobis and alternatively for a writ of certiorari was denied. View "Chatmon v. Arkansas" on Justia Law

Appellant Bruce Allen Echols was convicted by a jury of four counts of aggravated robbery and was sentenced to four concurrent terms of 360 months’ imprisonment. Echols filed a timely verified petition for postconviction relief pursuant to Rule 37.1 of the Arkansas Rules of Criminal Procedure (2015) and alleged that both trial counsel and appellate counsel1 were ineffective in litigating the factual and legal issues surrounding Echols’s arrest and the subsequent search of his residence. On September 24, 2015, the trial court entered its order summarily denying relief without a hearing. Finding that the trial court did not clearly err when it denied Echols' claims for postconviction relief, the Supreme Court affirmed. View "Echols v. Arkansas" on Justia Law

Appellant Anthony Randle was found guilty by jury of capital murder in the death of Ranson Harrison, for which he was sentenced to life imprisonment without parole. Randle appealed, and his conviction and sentence was affirmed by the Supreme Court. Randle filed a timely petition under Arkansas Rule of Criminal Procedure 37.1 (2008); however, the petition was not verified. In October 2015, the trial court denied relief, and Randle appealed. The State petitioned that the appeal be dismissed, arguing that Randle’s Rule 37.1 petition was not verified, which required dismissal of the appeal pursuant to Rule 37.1(d). The State additionally argued that Randle’s claim on appeal arose out of a pleading he filed challenging the State’s response to his Rule 37.1 petition. Because he had not sought leave to amend, Randle’s responsive pleading could not be considered an amended Rule 37.1 petition. Consequently, the State contended that appellate review of the claim was precluded because it was raised for the first time on appeal. After review, the Arkansas Supreme Court agreed with the State’s claims regarding dismissal of Randle’s appeal. View "Randle v. Arkansas" on Justia Law

In 2013, appellant Roy Russell was found guilty by a jury of second-degree battery and being a felon in possession of a firearm. He was sentenced as a habitual offender to serve 180 months’ imprisonment and 480 months’ imprisonment, respectively, to be served consecutively for a total of 660 months. The circuit court entered the sentencing order and stated each offense and sentence. The order also stated that the aggregate term of imprisonment to be served by Russell was 480 months, rather than the 660 months. A few weeks later, the circuit court entered an amended sentencing order that stated that a total sentence of 660 months’ imprisonment had been imposed. The Arkansas Court of Appeals affirmed the judgment. In 2016, Russell, filed a pro se petition for writ of habeas corpus alleging that he was being illegally held on an invalid conviction. Russell alleged that his 2013 sentencing order was invalid on its face and the circuit court lacked jurisdiction to enter the order. The circuit court denied Russell’s petition on the ground that Russell had not stated a ground for the writ. Russell appealed, contending the circuit court erred in denying his requested relief. Finding no reversible error, the Supreme Court affirmed. View "Russell v. Kelley" on Justia Law

Appellant Shawn Whiteside was an inmate incarcerated in the Arkansas Department of Correction (ADC). Whiteside filed a petition for judicial review of a decision by the Arkansas Parole Board (Parole Board). Whiteside alleged that the Parole Board considered him for parole and made a final decision declining to grant a transfer to the Department of Community Correction (DCC). He attached a copy of a document in support of that claim, a “Record of Release Consideration,” reflecting a hearing on May 24, 2015, and the denial of a request for reconsideration. Whiteside alleged deprivation of a conditional liberty interest in that the controlling statutes did not allow the ADC discretion in deferring a transfer for the offenses for which he was incarcerated. The circuit court dismissed the petition and counted it as a “strike” under Arkansas Code Annotated section 16-68-607 (Repl. 2005). The court found that Whiteside failed to state a claim on which relief could be granted in that Arkansas Code Annotated section 25-15-212(a) did not allow actions by persons incarcerated in the ADC and Whiteside had failed to demonstrate the requisite liberty interest in order to raise a due-process exception. Whiteside appealed the order, contending he indeed established a liberty interest to support his claim. The Arkansas Supreme Court has "repeatedly held that there is no liberty interest in parole in Arkansas." State statutes may create liberty interests that are entitled to the procedural protections of the Due Process Clause, but not every statute creates a liberty interest for due-process purposes. The Supreme Court found that even if Whiteside were correct in his claim that those inmates who meet the statute’s criteria have a statutorily created liberty interest in transfer or parole, he did not state facts to demonstrate that he has satisfied the statute’s criteria to be qualified for a mandatory transfer. Therefore, the Court affirmed dismissal of Whiteside's petition. View "Whiteside v. Ark. Parole Bd" on Justia Law

Dion Robinson was charged by information with committing four counts of aggravated robbery, four counts of felony theft of property, and one count of misdemeanor possession of marijuana. Robinson was incarcerated following a guilty plea, and the circuit court sentenced Robinson to a twenty-year sentence. All of the sentences were set to run concurrently. Robinson appealed the denial of his petition for post-conviction relief, arguing that the circuit court erred in not granting a hearing on his petition. Finding no error in the circuit court’s summary denial of Robinson’s petition, the Supreme Court affirmed. View "Robinson v. Arkansas" on Justia Law

Appellant Edward Reynolds appealed after a jury found him guilty of kidnapping and aggravated assault. He was sentenced as a habitual offender to consecutive sentences of life imprisonment and fifteen years’ imprisonment, respectively. On appeal, Reynolds contended that the circuit court erred by: (1) denying his directed-verdict motions on both charges; (2) allowing the victim to testify about her injuries despite the prosecutor’s failure to provide her medical records in discovery; and (3) overruling his objection to remarks made by the prosecutor during closing argument. Finding no error, the Supreme Court affirmed. View "Reynolds v. Arkansas" on Justia Law

After a jury trial, Appellant was found guilty of second-degree battery and of being a felon in possession of a firearm. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court ultimately concluded that Appellant’s claims were not supported by the record. The Supreme Court affirmed, holding (1) the trial court did not clearly err when it denied Appellant’s petition without conducting an evidentiary hearing; and (2) the trial court did not clearly err in concluding that counsel did not provide ineffective assistance. View "Russell v. State" on Justia Law

After a jury trial, Appellant was convicted of possession of methamphetamine, being a felon in possession of a firearm, and simultaneous possession of drugs and firearms. The court of appeals affirmed Appellant’s convictions and sentences. Appellant subsequently filed a timely postconviction petition alleging that the trial court was biased and that his two attorneys failed effectively to represent him. The trial court denied relief. The Supreme Court affirmed, holding (1) under Strickland v. Washington, Appellant failed to establish that he was prejudiced by his attorneys’ performance; and (2) the trial court did not err when it denied Appellant’s claim for postconviction relief without holding an evidentiary hearing. View "Stover v. State" on Justia Law

Corina Mendoza was a passenger in the backseat of a vehicle operated by Anthony Adams when Adams ran into the back of a parked excavator. Mendoza filed a complaint against Adams and WIS International, Inc. and Washington Inventory Services, Inc. (collectively, WIS) seeking damages for her injuries and alleging that Adams was acting in the course of his employment with WIS at the time of the accident. WIS and Adams pled the affirmative defense of comparative fault, citing Mendoza’s failure to wear a seat belt at the time of the accident. WIS and Adams then filed motions challenging the constitutionality of Ark. Code Ann. 27-37-703, which restricts the admissibility of seat belt nonuse in civil actions. The Supreme Court accepted a request from the district court to determine the certified question of whether section 27-37-703 is unconstitutional. The Supreme Court held that section 27-37-703 is procedural and therefore offends the principle of separation of powers under article 4, section 2 of amendment 80, section 3 of the Arkansas Constitution. View "Mendoza v. WIS Int’l, Inc." on Justia Law