Justia Constitutional Law Opinion Summaries

After a jury trial, Appellant was convicted of several drug-related sentences. The conviction was affirmed on appeal. Appellant subsequently filed a pro se petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding (1) the trial court did not err in not holding an evidentiary hearing on Appellant's petition; (2) the trial court did not err in failing to grant Appellant's petition based on his argument that trial counsel provided ineffective assistance by deciding not to call a certain witness; and (3) Appellant's third argument on appeal was without merit. View "Singleton v. State" on Justia Law

Appellant pleaded guilty to multiple felony offenses, including the Class Y felony offense of possession of methamphetamine with intent to deliver. The trial court later granted the State's petition to revoke the suspended imposition of sentence for the offenses on the ground that Appellant failed to comply with the conditions agreed upon when he entered the plea. Appellant appealed from the revocation order, and the court of appeals affirmed. Appellant later field a pro se petition for writ of habeas corpus alleging, as he had done on appeal from the revocation order, that the judgment-and-commitment order was invalid because the trial court had imposed a suspended sentence for the Class Y felony. The circuit court dismissed the petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to raise again the issue concerning the suspended sentence; and (2) even if the allegation raised by Appellant had not already been settled, Appellant failed to establish that the writ should issue. View "Loftis v. Hobbs" on Justia Law

In 1995, Appellant was convicted of first-degree murder. In 2012, Appellant filed a motion "challenging statutory construction and interpretation" and seeking a "judgment of acquittal" on his conviction. The circuit court treated the motion as one for habeas relief and then dismissed the motion. The Supreme Court dismissed Appellant's appeal, holding (1) the circuit court appropriately treated Appellant's motion as one for habeas relief; (2) because Appellant was not incarcerated within that circuit court's jurisdiction, the court did not have jurisdiction to grant habeas relief; and (3) Appellant's claim of insufficient evidence failed to state grounds for habeas relief. View "Hill v. State" on Justia Law

In 1995, Appellant was convicted of first-degree murder. More than fifteen years after the judgment had been entered, Appellant filed a motion to vacate, set aside, and discharge his conviction seeking fingerprint testing of the gun used in the murder under Act 1780 of 2001 Acts of Arkansas. There are a number of predicate requirements that must be met before a court can order testing under the Act, including the requirement that petitioners who file a motion for testing more than thirty-six months after the entry of the judgment of conviction rebut a presumption against timeliness. The circuit court denied the motion. The Supreme Court affirmed, holding that the trial court lacked jurisdiction under Act 1780 to grant relief on Appellant's motion because Appellant failed to rebut the presumption against timeliness. View "Hill v. State" on Justia Law

In 1995, Appellant was convicted of capital murder and sentenced to life imprisonment in the Grant County circuit court. In 2012, Appellant filed in the Grant County circuit court a motion seeking a hearing on the denial of his request to the Arkansas State Crime Laboratory under the Arkansas Freedom of Information Act (FOIA). The request sought a copy of fingerprint-analysis test results on a piece of evidence from the trial. The circuit court denied the motion. The Supreme Court dismissed the appeal, holding that, under Ark. Code Ann. 25-19-107(a), the Grant County circuit court lacked jurisdiction to hear Appellant's motion. The Supreme Court affirmed because Appellant was not incarcerated in Grant County. View "Hill v. State" on Justia Law

In 1985, Appellant was convicted of aggravated robbery, and in 1986, Appellant was convicted of a separate robbery. In 2010, Appellant filed a pro se petition for writ of habeas corpus, contending in the circuit court that the trial court in his cases lacked subject-matter jurisdiction because the felony informations were filed in the trial court without a preliminary probable-cause hearing having been held beforehand in municipal court. The Supreme Court affirmed, holding that because Appellant's claims did not challenge the facial validity of the judgment or demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Halfacre v. Hobbs" on Justia Law

Appellants filed four separate cases stemming from the Arkansas Department of Education's (ADE) administrative supervision of the Pulaski County Special School District (PCSSD) after the district was found to be in fiscal distress. In each of the cases, ADE filed a motion to dismiss, asserting that Appellants' claims for relief were barred by sovereign immunity because the complaints were brought against ADE regarding matters allegedly done in furtherance of ADE's official duties. The circuit court granted the motion in each of the four cases. Appellants appealed, asserting, inter alia, that the circuit court erred in dismissing ADE from their actions because the complaints alleged exceptions to the doctrine of sovereign immunity. The Supreme Court affirmed, holding that the circuit court did not err in granting ADE's motions to dismiss, as none of the recognized exceptions to the sovereign immunity doctrine applied in these cases. View "Fitzgiven v. Dorey" on Justia Law

After a jury trial, Petitioner was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Petitioner later filed a second petition seeking to have jurisdiction reinvested in the circuit court to consider a petition for writ of error coram nobis. Petitioner raised the same claims of a Brady violation and of ineffective assistance of counsel that he raised in his first petition. The Supreme Court denied the petition, holding that Petitioner failed to present any basis to reinvest jurisdiction in the circuit court to consider his petition for a writ of error coram nobis. View "Burgie v. State" on Justia Law

Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order was invalid on its face and that the circuit court lacked jurisdiction. The circuit court denied the petition. Appellant appealed and filed several motions and a petition for writ of mandamus related to the appeal. The Supreme Court dismissed the appeal and declared the motions and petition for writ of mandamus moot, holding that Appellant did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue because his claims did not challenge the facial validity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction. View "Burgie v. Hobbs" on Justia Law

Appellant pleaded guilty to rape. Consequently, the trial court revoked Appellant's probationary sentences for three counts of first-degree carnal abuse. Appellant was sentenced accordingly. The Arkansas Department of Correction (ADC) calculated that after serving seventy percent of his thirty-year sentence for the rape conviction, Appellant would be eligible for transfer. Appellant filed a pro se motion for declaratory judgment, contending that the ADC erred in its calculation of his transfer-eligibility date. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to show how the ADC miscalculated his transfer-eligiblity date in a manner inconsistent with the law in effect at the time he committed the rape. View "Anderson v. Hobbs" on Justia Law