Justia Constitutional Law Opinion Summaries
Articles Posted in Arkansas Supreme Court
Houston v. State
Appellant was convicted of first-degree murder in a shooting death and sentenced to 480 months' imprisonment. The conviction was affirmed on appeal. Appellant subsequently filed a petition for postconviction relief, which the trial court denied. Appellant appealed, contending, among other things, that trial counsel was ineffective for failing to have a gun tested that was discovered in another person's possession months after the murder. The Supreme Court reversed, holding that the trial court clearly erred in finding that counsel's decision not to test the gun was reasonable, and the additional evidence may have changed the outcome of the trial. Remanded. View "Houston v. State" on Justia Law
Hill v. State
After a trial, Appellant was conviction of first-degree murder and sentenced as a habitual offender to 720 months' imprisonment. No appeal was taken from the judgment. Appellant subsequently filed a writ of error coram nobis, raising a number of claims. The trial court denied the writ. Appellant appealed, raising as his sole point on appeal an allegation of error concerning a claim of withheld evidence. The Supreme Court affirmed, holding that the trial court did not err in denying coram nobis relief where Appellant's pleading failed to demonstrate that the evidence he contended was withheld was sufficient to support issuance of the writ. View "Hill v. State" on Justia Law
Gulfco of La. Inc. v. Brantley
Appellant was in the business of extending high-risk loans to customers with poor credit ratings and operated primarily in Louisiana. Appellees, who resided in Arkansas, obtained four loans from Appellant at its location in Louisiana. After Appellees failed to make payments on the loans, Appellant filed in an Arkansas circuit court a notice of default and intention to sell Appellees' home. Appellees asserted the defenses of usury, unconscionability, esoppel, unclean hands, predatory lending practices, and a violation of the Arkansas Deceptive Trade Practices Act. The circuit court found that the loans constituted predatory lending by a foreign corporation not authorized to do business in Arkansas and that the contract between the parties was unconscionable and could not be given full faith and credit. The Supreme Court affirmed, holding (1) the circuit court's findings of unconscionability and predatory lending practices were not clearly erroneous; and (2) court did not err in refusing to enforce the mortgage, as to do so would contravene the public policy of the State of Arkansas. View "Gulfco of La. Inc. v. Brantley" on Justia Law
Dotson v. State
Appellant pleaded guilty to possession of a controlled substance and the manufacture, delivery, or possession of marijuana and was sentenced to 120 months' incarceration. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of counsel and due-process and equal-protection violations. The trial court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant could not prevail on his claim of ineffective assistance of counsel because he failed to demonstrate that the argument he contended counsel should have made had merit; and (2) to the extent that Appellant's independent constitutional claims may have been cognizable in a postconviction proceeding, the claims failed because the basis of Appellant's claims was without merit. View "Dotson v. State" on Justia Law
Cooper v. Circuit Court
The City of Conway and Conway Corporation (collectively, "Conway") filed a land condemnation action against Petitioners, property owners. The morning of trial, Petitioners requested a continuance. The circuit court granted the continuance on the condition that Petitioners would be responsible for Conway's attorney's fees and costs associated with preparing for the trial. The continuance order also prohibited Petitioners from filing any additional pleadings until the attorneys' fees and costs were paid. Petitioners subsequently filed this motion for writ of prohibition or, in the alternative, writ of certiorari to rescind the order. The Supreme Court denied the writ of prohibition but granted the writ of certiorari, holding that the circuit court exceeded its jurisdiction and committed a manifest, clear and gross abuse of discretion in ordering Petitioners to pay Conway's attorney's fees and costs. View "Cooper v. Circuit Court" on Justia Law
Benton v. State
After a jury trial, Appellant was convicted of second-degree forgery and theft by receiving. Appellant appealed, arguing that there was insufficient corroboration to support the forgery conviction and insufficient evidence to sustain the theft-by-receiving judgment. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus repeating the arguments he raised on appeal. Appellant also argued that the evidence adduced at his trial was insufficient to sustain the convictions, that the trial court erred by denying certain motions and admitting inadmissible evidence, and that the court of appeals erred in affirming the judgment. The circuit court denied the habeas petition. The Supreme Court affirmed, holding that Petitioner failed to raise a claim within the purview of a habeas petition, and therefore, he failed to demonstrate a basis for the writ to issue. View "Benton v. State" on Justia Law
Banks v. Hobbs
In 1999, Appellant was convicted of rape and sentenced as a habitual offender to a term of forty years imprisonment. In 2000, Appellant was convicted of first-degree battery and sentenced as a habitual offender to sixty years' imprisonment, with the term to run concurrently with the previously imposed sentence. In 2010, Appellant filed a petition for writ of mandamus, contending that the records supervisor at the prison facility where he was an inmate would not credit him with his earned meritorious good time for purposes of determining parole eligibility. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's brief was insufficient for review and that Appellant failed to show he was entitled to a writ of mandamus.
View "Banks v. Hobbs" on Justia Law
Zachry v. Hobbs
Appellant filed a pro se petition for writ of habeas corpus in the Jackson County Circuit Court, stating that she was incarcerated at a facility in Jackson County. Appellant was subsequently transferred to a facility in a different county. The Supreme Court dismissed the appeal, holding that because a circuit court does not have jurisdiction to release on a writ of habeas corpus a prisoner not in custody in that court's jurisdiction, the Jackson County Circuit Court lacked personal jurisdiction over Petitioner where she was no longer incarcerated in the county where her petition was filed. View "Zachry v. Hobbs" on Justia Law
Williamson v. State
After a jury trial, Appellant was convicted of first-degree murder and of using a firearm during the commission of the felony. Appellant appealed, arguing that there was insufficient evidence to support his conviction and that the trial court erred in denying his motion to suppress his confession made to police. The Supreme Court affirmed, holding (1) The State offered substantial evidence of Appellant's intent to commit first-degree murder; and (2) the trial court did not err in denying Appellant's motion to suppress or in finding Appellant's waiver of his Miranda rights was voluntarily, knowingly, and intelligently made. View "Williamson v. State" on Justia Law
State v. V.H.
In 2003, the county prosecutor filed a delinquency petition against Appellee, who was sixteen years old at the time. Appellee later pled no contest to the charge of sexual assault in the second degree, and the circuit court entered an order adjudicating Appellee delinquent. After Appellee was released from the custody of youth services, the circuit court ordered Appellee to register as a moderate-risk sex offender. Two years later, Appellant unsuccessfully filed a petition requesting that his name be removed from the sex-offender registry. After Appellee had turned twenty-one, he filed a petition again requesting that he no longer be required to register as a sex offender or that his name appear on the registry. The State filed a motion to dismiss, arguing, inter alia, that the circuit court lacked jurisdiction to consider Appellee's petition because he was no longer a juvenile. The circuit court released Appellee of his requirement to register and removed his name from the sex-offender registry. The State appealed. The Supreme Court affirmed, holding that the State's arguments on appeal lacked merit. View "State v. V.H." on Justia Law