Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing without prejudice Appellants' claims against Appellees, the Board of Trustees of the University of Arkansas System and others, holding that the circuit court did not err by determining that Appellants lacked standing and that their claims were unripe and nonjusticiable.Appellants, tenured factual members employed by the University of Arkansas System, filed on behalf of themselves and all others similarly situated a complaint against the Board seeking declaratory and injunctive relief based on alleged violations of both federal and state law. The Board filed a motion to dismiss, arguing that claims should be dismissed based on lack of standing, unripeness, and failure to state a claim. The circuit court granted the motion. The Supreme Court affirmed, holding that the circuit court correctly dismissed Appellants' claims. View "Palade v. Board of Trustees" on Justia Law

The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder, kidnapping, aggravated robbery, and theft of property but remanded for the circuit court to correct the sentencing order, holding that there was no reversible error.Specifically, the Supreme Court held (1) the circuit court did not err in denying Appellant's motion for directed verdict on the capital-murder, kidnapping, and aggravated-robbery charges; (2) the circuit court did not abuse its discretion in denying Defendant's motion to suppress; (3) due to a discrepancy between the sentencing order and the pronouncement of sentence, this matter must be remanded for the court to correct the order; (4) the circuit court did not abuse its discretion in admitting three exhibits over Appellant's hearsay objections; (5) the circuit court did not abuse its discretion by allowing the State to question Appellant about three prior bad acts; and (6) Appellant was not entitled to relief on his remaining claims of error. View "Smith v. State" on Justia Law

The Supreme Court reversed the order of the circuit court enjoining the enforcement of the Bentonville School District's mask policy in favor of Plaintiffs, parents of school children, holding that the the circuit court abused its discretion in granting Plaintiffs' motion for a temporary restraining order (TRO).In granting the TRO, the circuit court concluded that the school policy at issue violated Plaintiffs' right under Ark. Const. art. II, 21 and 29 to care for their children and that the District lacked the authority to issue the mask policy. The Supreme Court reversed, holding that (1) the circuit court abused its discretion in finding that the policy violated Plaintiffs' constitutional rights and was enacted without proper authority; and (2) Plaintiffs failed to show that irreparable harm would result in the absence of a TRO. View "Bentonville School District v. Sitton" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.After a jury trial, Appellant was convicted of aggravated robbery and theft of property. In his pro se petition for writ of habeas corpus Appellant argued that a different standard of review should be applied to habeas cases, he was actually innocent, his constitutional rights were violated, and the evidence was insufficient to sustain his conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ or that the circuit court erred by denying habeas relief. View "Boyd v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellants' motion for an emergency injunction that sought the removal of three members of the Eureka Springs City Advertising and Promotion Commission (CAPC), holding that there was no error.On appeal, Appellants argued (1) Carol Wright's appointment to the CAPC violated Ark. Const. art. 19, 3, and (2) the appointments of Melissa Green and Harry Meyer to the CAPC violated Ark. Code Ann. 14-4-107(a)(2). The Supreme Court affirmed, holding (1) the circuit court correctly concluded that Wright's CAPC appointment was not constitutionally prohibited; and (2) the circuit court did not err when it determined that Green and Meyer were qualified to serve as CAPC commissioners despite being sitting council members at the time of their appointments. View "Johnson v. Wright" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the circuit court denying the State's motion to dismiss and granting a preliminary injunction in favor of Plaintiff, holding that the preliminary injunction was granted erroneously.Plaintiff, a hearing-instrument dispenser whose license was not renewed, brought this action against the Arkansas Department of Health, the Secretary of Health, and Arkansas Board of Hearing Instrument Dispensers, and the Executive Director of the Board of Hearing Instrument Dispensers (collectively, the State), arguing that the Board's refusal to provide him a proper renewal notice and a hearing violated his due process and equal protection rights and was an arbitrary and capricious abuse of the Board's power. The circuit court granted Plaintiff's request for a temporary injunction and declaratory relief. The Supreme Court reversed in part, holding (1) Plaintiff adequately pleaded a due process claim; (2) Plaintiff's equal protection claim was barred by sovereign immunity; and (3) because the preliminary injunction order contained no findings on irreparable harm or likelihood of success on the merits, the case must be remanded for findings in accordance with Ark. R. Civ. P. 65(d)(1). View "Arkansas Department of Health v. Solomon" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying John Thurston's motion to dismiss this action based on sovereign immunity, holding that Thurston was not entitled to sovereign immunity.Plaintiffs, the League of Women Voters of Arkansas and Arkansas United and several individuals, filed suit against Defendants, including Thurston in his official capacity as the Secretary of State, alleging that four acts passed by the 93rd Session of the Arkansas General Assembly were unconstitutional. Thurston filed a motion to dismiss based on sovereign immunity, which the circuit court granted. The Supreme Court affirmed, holding that Thurston was not entitled to sovereign immunity under the facts of this case. View "Thurston v. League of Women Voters of Ark." on Justia Law

The Supreme Court affirmed the supplemental order of the circuit court denying Ark. R. Crim. P. 37 relief, holding that the circuit court did not err.Defendant was convicted of capital murder and sentenced to death. Defendant later sought postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding (1) Defendant was not denied the right to a fair and impartial jury; (2) the circuit court did not clearly err in denying Defendant's ineffective assistance of counsel arguments; (3) Defendant's challenges to the third death-penalty verdict form did not constitute grounds for relief under Rule 37; (4) Defendant's challenges to the verdict forms did not constitute grounds for relief; and (5) Defendant's remaining allegations of error were without merit. View "Gay v. State" on Justia Law