Justia Constitutional Law Opinion Summaries

After a jury trial in 2001, Appellant was found guilty of four counts of aggravated robbery, three counts of misdemeanor theft of property, and one count of felony theft of property. In 2013, Appellant filed a motion under Ark. Code Ann. 16-112-202 seeking fingerprint testing, DNA testing, and further examination of a videotape. Approximately three weeks later, Appellant filed a “motion for a new trial,” requesting that the videotape be tested under Ark. Code Ann. 16-112-208 and again requesting fingerprint and DNA testing. The trial court denied both pleadings on the ground that the two pleadings were successive habeas pleadings and subject to denial under Ark. Code Ann. 16-112-205(d). The Supreme Court affirmed, holding that the trial court did not err in denying the pleadings. View "Hutcherson v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. The Supreme Court affirmed. Sixteen years after the judgment had been entered, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, asserting that he was actually innocent of the murder and seeking DNA testing of blood on an article of clothing. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish good cause for the lengthy delay in filing his petition and that Appellant’s claim of ineffective assistance of counsel was not properly before the Court. View "Hussey v. State" on Justia Law

After a jury trial, Appellant was found guilty of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. The court of appeals affirmed. Appellant sought postconviction relief pursuant to Ark. R. Crim. P. 37.1, without success. Thereafter, Appellant, who was incarcerated at a prison facility in Lee County, filed in the Drew County Circuit Court a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, alleging that there was scientific evidence to demonstrate that he was actually innocent of the offenses of which he was convicted and that his sentence was illegal. The trial court denied the petition. Supreme Court dismissed Appellant’s appeal on the basis that the habeas petition was filed in the wrong court. View "Darrough v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder and sentenced to eighty years in prison. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37 alleging ineffective assistance of counsel. The circuit court granted relief and ordered a new trial, concluding that Appellant’s trial counsel was ineffective for failing to renew a challenge to the circuit court’s decision to exclude evidence of the victim’s prior act of violence, thus depriving Appellant of his opportunity to present a complete defense. The Supreme Court reversed, holding that the circuit court’s initial decision to exclude the evidence was not in error, and therefore, there was no basis on which to grant postconviction relief. View "State v. Rainer" on Justia Law

Appellant was convicted on two counts of capital murder and sentenced to life imprisonment. Appellant filed a petition for writ of habeas corpus setting forth a number of allegations or error. The circuit court dismissed the petition on the grounds that Appellant failed to establish probable cause for a writ of habeas corpus to issue. The Supreme Court affirmed, holding (1) Appellant’s arguments concerning the validity of the charging instruments, intertwined with other arguments concerning trial error, failed; and (2) the remainder of Appellant’s arguments were not grounds for issuance of a writ of habeas corpus. View "Sanders v. Straughn" on Justia Law

After a jury trial, Petitioner was found guilty of two counts each of attempted first-degree murder and first-degree battery. The court of appeals affirmed. Petitioner subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that, based on a totality of the evidence, the trial court did not clearly err in denying Petitioner’s petition, as Petitioner did not meet his burden of overcoming the presumption that his trial counsel was effective. View "Robinson v. State" on Justia Law

Appellant was charged with the capital murder of his two-year-old stepdaughter. After jury selection for Appellant’s trial began, the parties reached a plea agreement under which Appellant agreed to plead guilty to first-degree murder and be sentenced by the as yet unsworn jury. After a sentencing trial, the jury sentenced Appellant to life imprisonment. Appellant appealed his sentence, arguing that the circuit court erred in denying his request to conduct additional voir dire of the selected but unsworn jury after the plea agreement had been consummated. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion or violate Appellant’s rights to due process and an impartial jury in refusing to allow additional proffered voir dire. View "Pedraza v. State" on Justia Law

After a jury trial, Appellant was convicted of premeditated and deliberate capital murder and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in refusing to allow defense counsel to impeach a State witness with his prior acts of untruthfulness; (2) the circuit court did not abuse its discretion when it prevented Appellant from impeaching the sole eyewitness with his prior inconsistent statements; (3) the circuit court did not err in denying Appellant’s motion for mistrial based on discovery violations; (4) the overlap of the capital murder and first-degree murder statutes does not violate the Arkansas Constitution; (5) the circuit court’s statements revealing irritation of defense counsel’s tactics did not warrant reversal; and (6) Appellant’s argument that the circuit court abused its discretion in failing to conduct a Daubert hearing before admitting expert testimony about a palm print found at the scene of the murder and identified as Appellant’s was precluded from review. View "Maiden v. State" on Justia Law

After a jury trial, Appellant was found guilty of aggravated robbery and commercial burglary and sentenced to an aggregate term of 240 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance and that the evidence was insufficient to sustain the convictions. The trial court denied the petition. The Supreme Court dismissed the appeal and mooted the motion Appellant filed in relation to the appeal, holding that the trial court did not clearly err in concluding that trial counsel’s performance was not ineffective. View "Thomas v. State" on Justia Law

Appellant entered a negotiated plea of guilty to first-degree murder and possession of firearms by a certain person and was sentenced as a habitual offender to an aggregate term of 420 months’ imprisonment. Appellant subsequently filed a petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The circuit court denied relief without a hearing. The Supreme Court dismissed the appeal and mooted the motion filed in relation to the appeal, holding that Appellant failed to meet his burden of proving prejudice from any deficient performance on the part of trial counsel. View "Robinson v. State" on Justia Law