Justia Constitutional Law Opinion Summaries

After a jury trial, Defendant was convicted of rape. Defendant was sentenced to ten years in prison. The court of appeals affirmed the conviction. Defendant subsequently filed a petition for postconviction relief arguing that he received ineffective assistance of counsel because his defense counsel failed to object to testimony that allegedly bolstered the victim’s credibility. The circuit court denied Defendant’s claim, concluding that defense counsel’s failure to object was based on trial strategy and that his performance was not deficient. The Supreme Court affirmed, holding that the circuit court did not err in finding that counsel’s failure to object was based on trial strategy. View "Fukunaga v. State" on Justia Law

After a jury trial, Appellant was convicted of three counts of rape. Appellant was sentenced to consecutive terms of imprisonment of life, fifty years, and fifty years. Appellant appealed, contending that the trial court committed a speedy trial violation and did not follow the strict dictates of Ark. R. Crim. P. 28.3(b)(1). The Supreme Court affirmed, holding that Appellant’s trial date was well within the one-year period for a speedy trial, as the State met its burden to prove that any delay was excludable for speedy-trial purposes, and therefore, there was no speedy-trial violation in this case. View "Carter v. State" on Justia Law

Plaintiffs, three Arkansas corporations that operate private hospitals in the state, filed a complaint for declaratory judgment seeking a judgment declaring the Arkansas Peer Review Fairness Act unconstitutional. The circuit court ruled that the Act is not unconstitutional. Defendants - the Attorney General, the Arkansas Department of Health, and Nathaniel Smith - appealed, arguing that there was no actual, present controversy in this case because there was no present danger or dilemma. The Supreme Court reversed, holding that this was not a proper declaratory judgment action because the necessary element of a justiciable controversy was lacking in this case. View "Baptist Health Sys. v. Rutledge" on Justia Law

Appellant was convicted of kidnapping, aggravated residential burglary, and other offenses. Appellant was sentenced to fifty-two years’ imprisonment, which included a firearm enhancement. The court of appeals affirmed. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The circuit court denied relief without holding a hearing. The Supreme Court affirmed, holding (1) Appellant did not establish that his trial counsel was ineffective for failing to pursue and actual-innocence defense where Appellant’s counsel actually pursued an actual-innocence defense at trial; (2) Appellant failed to demonstrate prejudice due to trial counsel’s failure to move for a change of venue; (3) Appellant’s sentence for employing a firearm in the commission of an offense was not void as the result of ineffective assistance of trial counsel; and (4) considering the totality of the evidence, the circuit court did not clearly err in denying Appellant’s request for an evidentiary hearing. View "Van Winkle v. State" on Justia Law

After a second jury trial, Appellant was convicted of four counts of rape. The court of appeals affirmed. Appellant subsequently filed an Ark. R. Crim. P. 37 petition, alleging ineffective assistance of counsel. Appellant’s petition contained three allegations of deficient performance during the second jury trial. The circuit court denied the petition without a hearing, concluding that the first allegation was conclusory and the remaining allegations were matters of trial strategy and could not form the basis for postconviction relief. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the circuit court correctly found that the first allegation could not form the basis for postconviction relief; but (2) Appellant’s second and third claims for relief based on ineffective assistance of counsel were colorable claims. Remanded for a hearing on Appellant’s second and third claims. View "Sandrelli v. State" on Justia Law

Appellant filed an illegal-exaction lawsuit against The Oxford American Literary Project, Inc. In his complaint, Appellant asserted that the University of Central Arkansas loaned $700,000 to Oxford American out of its cash funds and that the loan was an improper use of cash funds. The circuit court granted summary judgment in favor of Oxford American, concluding that the funds were not funds derived from taxes and were therefore not subject to an illegal exaction suit. The Supreme Court affirmed, holding that summary judgment was proper because the undisputed facts showed that the cash funds at issue were not generated from and did not arise from taxation. View "McCafferty v. Oxford Am. Literary Project, Inc." on Justia Law

After a jury trial, Defendant was convicted of capital murder. The jury sentenced Defendant to death. The Supreme Court affirmed. Thereafter, Defendant filed a petition pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court granted Defendant a new sentencing hearing based on counsel’s admission that his performance had been inadequate. The court, however, denied Defendant relief on the basis that counsel should have presented a defense of mental disease or defect. The State appealed from the first finding, and Defendant appealed from the second finding. The Supreme Court (1) reversed on appeal, holding that the circuit court analyzed the case under a subjective legal standard rather than assessing counsel’s performance under an objective standard; and (2) affirmed on cross-appeal, holding that the circuit court did not err in denying relief based on counsel’s failure to present an affirmative defense. View "State v. Lacy" on Justia Law

Appellant was convicted of possession of a Schedule III substance with the purpose to deliver, possession of a Schedule III substance, and possession of drug paraphernalia. Appellant appealed the denial of his motion to suppress evidence obtained as a result of a canine sniff conducted after he was pulled over for failing to use a turn signal. The Supreme Court reversed Appellant’s convictions and sentence, holding that the circuit court erred in denying Appellant’s motion to suppress where the canine sniff was conducted after Appellant’s continued detention that was conducted without reasonable suspicion. View "MacKintrush v. State" on Justia Law

Plaintiffs in this case were three female same-sex married couples and their children. One spouse in each married couple gave birth to a child, but the Arkansas Department of Health declined to issue a birth certificate with both spouses listed as parents. Plaintiffs filed suit seeking a declaration that Defendant, the Director of the Department, violated their constitutional rights and that certain statutory provisions were unconstitutional. After a hearing, the circuit court announced its intention to order the Department to amend the birth certificates of the child-plaintiffs. Before the written order was entered, Defendant requested a stay pending appeal. The circuit court denied Defendant’s request, ordered Defendant to issue amended birth certificates to Plaintiffs, and struck portions of a statute and made substantial additions to a provision of the Arkansas Code. The Supreme Court (1) denied the petition for emergency stay as to the portions of the order and memorandum opinion ordering Defendant to provide amended birth certificates to Plaintiffs, as Defendant did not challenge this portion of the order; but (2) granted the petition as to the remainder of the order and memorandum opinion, holding that it was best to preserve the status quo ante with regard to the statutory provisions while the Court considered the circuit court’s ruling. View "Smith v. Pavan" on Justia Law

Appellant entered a conditional plea of guilty to a charge of driving while intoxicated, sixth offense. Appellant appealed, arguing that his conviction violated the ex post facto clauses of the Arkansas Constitution and United States Constitution. This appeal presented an issue of first impression whether an appeal was allowed from Appellant’s conditional plea. The Supreme Court affirmed, holding (1) under the circumstances of this case, the Court has jurisdiction to consider the appeal; and (2) as to the merits, Appellant’s conviction does not violate the ex post facto clauses of the United States Constitution and Arkansas Constitution. View "Laymon v. State" on Justia Law