Justia Constitutional Law Opinion Summaries

Petitioner was arrested in 2011 and detained in jail, where he remained since his arrest. Petitioner was later charged with aggravated robbery and capital murder. In 2013, Petitioner filed a second amended petition for writ of habeas corpus against the county sheriff, seeking his release from custody and asserting that his continued detainment violated his due process rights because the prosecutor announced there was insufficient evidence to move forward with the case. The Supreme Court denied the petition because none of the allegations raised by Petitioner called into question the trial court's jurisdiction or established that the commitment was invalid on its face. View "Smith v. Smith" on Justia Law

After a trial in the Saline County Circuit Court in 1987, Appellant was convicted of kidnapping and sentenced to 240 months' imprisonment. In 2013, Appellant filed a "motion to order release due to court order from 1996" in the circuit court in Lee County, where he was in custody. The circuit court denied the petition, concluding that it constituted a challenge to the judgment of conviction entered in the Saline County trial court and should have been filed there. The Supreme Court affirmed, holding that whether Appellant's motion was intended to be in the nature of a petition for writ of habeas corpus or a petition for postconviction relief, the circuit court was not wrong to dismiss the motion. View "Zulpo v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed on appeal. Prior to issuance of the mandate, Appellant filed a pro se petition for postconviction relief, alleging that his counsel had provided constitutionally deficient assistance for several reasons. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant's appeal and moot his motion for extension of time to file his brief because it was clear Appellant could not prevail if his appeal were permitted to go forward. View "Jordan v. State" on Justia Law

Petitioner filed a pro se petition for writ of habeas corpus in the circuit court in Lee County, where he was incarcerated. Thereafter, Petitioner was transferred to a facility in a different county. The circuit court dismissed Petitioner's petition. Petitioner filed a notice of appeal and moved to proceed with a belated appeal and to complete the record. The Supreme Court dismissed the motion for belated appeal and mooted the motion to complete the record, holding that because Petitioner was not in custody in the Lee County Circuit Court's jurisdiction, the Lee County Circuit Court did not retain personal jurisdiction over Petitioner and could no longer grant the relief sought. View "Fields v. State" on Justia Law

Appellant, an inmate incarcerated in the Arkansas Department of Correction (ADC) at a facility in Lincoln County, filed a pro se petition for writ of habeas corpus in the Pulaski County Circuit Court. Thereafter, Appellant filed a motion to dismiss the habeas petition and filed a second petition for habeas corpus. Appellant subsequently filed a series of motions and pleadings in the case. The circuit court dismissed the first habeas petition, denied the second habeas petition, and denied or dismissed motions and pleadings filed in the habeas proceeding. The Supreme Court dismissed Appellant's appeal and held the motion related to the appeal moot, holding that because Appellant was not incarcerated in Pulaski County, the Pulaski County Circuit Court did not have jurisdiction to release Appellant on a writ of habeas corpus. View "Pitts v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree sexual assault and sexual indecency with a child. Appellant later filed a pro se petition for declaratory judgment and for writ of mandamus seeking to challenge the calculation of his parole eligibility. The circuit court dismissed the petition. Appellant appealed and filed a pleading arguing that his sentence should be dismissed as unconstitutional on the ground that the trial judge did not follow federal sentencing guidelines. Appellant also argued that the circuit court lacked jurisdiction and that he was being held pursuant to an invalid conviction. The Supreme Court dismissed the motion and affirmed the circuit court's order, holding that Appellant failed to show he was entitled to declaratory judgment or a writ of mandamus, and his motion was without merit. View "Pitts v. Hobbs" on Justia Law

After a jury trial, Appellant was found guilty of the rape of his stepdaughter and sentenced to 156 months' imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his counsel provided ineffective assistance, for, among other things, deciding not to introduce a recording into evidence for the purpose of impeaching the victim. The trial court found that Appellant was not entitled to relief on the allegation because Appellant failed to identify specific evidence that would have changed the outcome of the trial and because the introduction of evidence is a matter of trial strategy. The Supreme Court reversed the trial court on this point and remanded for an evidentiary hearing, as it was not apparent from the face of the petition or the record that Appellant was not entitled to relief on this allegation. View "Lemaster v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder for the death of his twenty-three-month-old son and sentenced to life imprisonment without parole. On appeal, Appellant argued that the circuit court erred by removing a juror without justification. The juror had spoken with prospective witnesses during trial proceedings and denied to the court that she had spoken with any witnesses. The circuit court removed the juror and replaced her by an alternate juror. The Supreme Court affirmed the conviction and sentence, holding that the circuit court did not abuse its discretion in removing the juror and seating an alternate. View "Ingram v. State" on Justia Law

After a jury trial, Appellant was convicted of failing to comply with registration and reporting requirements applicable to sex offenders and with residing within 2000 feet of a daycare facility as a level-4 sex offender. Appellant later filed a petition for postconviction relief, raising a number of claims stemming from the State's introduction of a risk assessment and offender profile report into evidence during the sentencing phase at trial and alleging that counsel was ineffective for several reasons. The trial court denied the petition without a hearing. The Supreme Court affirmed and held the motions related to the appeal moot, holding that because the record demonstrated that Appellant's petition did not set forth any meritorious claim under Ark. R. Crim. P. 37.1, the trial court did not err in dismissing the petition without a hearing. View "Green v. State" on Justia Law

After a jury trial, Appellant was convicted of the offense of being a felon in possession of a firearm and was sentenced as a habitual offender to a term of imprisonment. Appellant later filed an amended pro se petition for writ of habeas corpus contending that the convictions for the underlying felonies to the charge of being a felon in possession of a firearm were illegally obtained and that the evidence was insufficient to sustain the convictions for the underlying felonies. The circuit court dismissed the habeas petition. The Supreme Court dismissed Appellant's appeal and held Appellant's motion for extension of time to file his brief-in-chief moot, holding that Petitioner failed to raise a claim within the purview of a habeas action and therefore failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Glaze v. Hobbs" on Justia Law