Justia Constitutional Law Opinion Summaries

In this school-funding dispute, a school district (District) filed an action on its own behalf and on behalf of its taxpayers to enjoin state actions in violation of state law and the Arkansas Constitution. The District alleged two claims against Appellees. The District then voluntarily nonsuited the special-and-local legislation claim so it could immediately appeal the adequacy claim in the "Beebe" case. The District brought the special-and-local-legislation claim as a separate case in the "Kimbrell" case. The Supreme Court dismissed the appeal of the Beebe case for a lack of finality. The circuit court subsequently consolidated the Beebe case and the Kimbrell case. After the circuit court decided the cases, the District appealed. The Supreme Court affirmed in part, reversed and remanded in part, and mooted in part, holding (1) the circuit court abused its discretion in ruling that some of the District's claims in the Beebe case were barred by res judicata but did not err in dismissing the District's other claims as barred by res judicata; (2) the circuit court did not err in striking the District's amended and supplemental complaint; and (3) the District's claims in the Kimbrell case were moot. View "Deer-Mt. Judea Sch. Dist. v. Kimbrell" on Justia Law

Petitioner filed a pro se petition for writ of error coram nobis in his criminal case, which was denied. Petitioner subsequently filed a motion for belated appeal in order to challenge the order denying his motion. Plaintiff, however, sought to appeal without a certified record or, in the alternative, sought an order directing the circuit clerk to provide the certified record necessary to file the motion for belated appeal. The Supreme Court denied the motion because Petitioner failed to meet his burden of providing a certified record with a motion for belated appeal sufficient to establish the Supreme Court's jurisdiction and sufficient to allow the Court to rule on the merits of his motion. View "Bannister v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder, committing a terroristic act, and using a firearm during the commission of a felony. Appellant was sentenced to life imprisonment plus a term of ten years. Appellant appealed, arguing that the circuit court erred in excluding Ark. R. Evid. 404(b) testimony about the alleged bad acts by the State's primary eyewitness. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in excluding the evidence because Appellant failed to show that the testimony regarding the eyewitness's bad acts was relevant to any material issue in this case. View "Allen v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced to 720 months' imprisonment. Appellant subsequently filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, raising several grounds for relief. The trial court denied the petition. Appellant appealed, arguing that his counsel provided ineffective assistance. The Supreme Court affirmed, holding (1) because Appellant did not raise his ineffective assistance of counsel claim in the postconviction petition, the argument would not be addressed by the Court on appeal; and (2) to the extent Appellant argued that the evidence was insufficient to sustain the judgment, Rule 37.1 does not provide a means to attack the weight of the evidence to support the conviction. View "Williams v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree. The jury declared that Appellant's sentence of 480 months' imprisonment should be enhanced by an additional term of 180 months' imprisonment for use of a firearm in the commission of the felony. The sentences were to be served consecutively. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging, among other claims, that the trial court erred when it accepted the jury's recommendation and ordered the sentences to be served consecutively. The circuit court denied the petition. The Supreme Court affirmed, holding that because Appellant's claims did not demonstrate the facial invalidity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Tate v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of rape and sentenced to two consecutive life sentences. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging a number of grounds for relief. The circuit court dismissed the petition without a hearing. Appellant appealed, stating that he was entitled to habeas relief based on, inter alia, violations of due process, prosecutorial misconduct, and ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the circuit court did not err by not conducting a hearing, as Appellant failed to demonstrate probable cause for the issuance of the writ; (2) the circuit court did not err by not making extensive written findings to support its decision; (3) several of Appellant's arguments on appeal were barred by the law-of-the-case doctrine; and (4) Appellant's reviewable claims were without merit. View "Strong v. Hobbs" on Justia Law

After a jury trial, Defendant was convicted of several felonies and sentenced to life imprisonment as a habitual offender. The Supreme Court affirmed on appeal, holding (1) the circuit court did not err in denying Defendant's motion to dismiss on speedy-trial grounds, as there was no speedy-trial violation in this case; and (2) the two fifteen-year sentences imposed on Defendant for having used a firearm to commit aggravated robbery and theft of property were not illegal, as Defendant failed to demonstrate that the Court's holding in Williams v. State, in which the Court addressed the issue, was patently wrong or manifestly unjust. View "Smith v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. Appellant appealed, arguing (1) the circuit court should have granted his motion for acquittal because at the time of the charged conduct, he lacked capacity as a result of mental disease or defect to conform his conduct to the requirements of the law or to appreciate the criminality of his conduct; and (2) the circuit court erred in denying his motion for a mistrial after the jury announced that it was deadlocked. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in denying Appellant's motion for acquittal; and (2) Appellant's second argument was not preserved for appellate review. View "Russell v. State" on Justia Law

Appellant pled guilty to multiple felony offenses and was sentenced to an aggregate term of 420 months' imprisonment. Appellant subsequently filed in the Mississippi County trial court a pro se petition for writ of habeas corpus and a pro se motion to rescind the plea agreement he entered when he pled guilty. Appellant was incarcerated in Lee County when he filed the habeas corpus petition. The trial court denied both pleadings. The Supreme Court affirmed, holding that because Appellant was not incarcerated within the jurisdiction of the trial court in Mississippi County when he filed the petition, the court did not have personal jurisdiction to issue and make returnable a writ. View "Rivers v. State" on Justia Law

Appellant pled guilty to capital murder and was sentenced to life imprisonment without parole. Appellant later filed a pro se petition for writ of habeas corpus, arguing that he was insane or mentally incompetent at the time he entered his plea and that the trial court was deprived of jurisdiction to try an insane or mentally incompetent person. The circuit court declined to issue the writ. The Supreme Court affirmed, holding that because Appellant's petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court's jurisdiction, Appellant failed to establish a basis for a writ of habeas corpus to issue. View "Matthews v. Hobbs" on Justia Law