Justia Constitutional Law Opinion Summaries

After a bench trial, Defendant was convicted of rape. Defendant subsequently filed a petition for postconviction relief, alleging that he was afforded ineffective assistance of counsel. The circuit court denied the petition. Defendant appealed and filed motions for an extension of time to file his brief-in-chief and for a copy of the record on appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that Defendant failed to provide facts affirmatively supporting the claims that his counsel's conduct prejudiced him under the standards set out in Strickland v. Washington. View "Stevenson v. State" on Justia Law

In 1994, Defendant pled guilty to attempted rape and to violation of a minor. Defendant committed the offenses in 1992 or 1993. Defendant was sentenced to concurrent terms of twenty years' imprisonment for the attempted rape charge. In 2010, Defendant filed a pro se petition to correct an illegal sentence, arguing that his twenty-year sentence amounted to an ex-post-facto violation because the court applied the transfer-eligibility statute, which became effective in 1994, to his sentence. Specifically, Defendant alleged that the parole-eligibility statute in effect at the time of the commission of the crime should be applied to his sentence. The circuit court denied Defendant's petition. The Supreme Court affirmed, holding that because Appellant's petition was untimely, the circuit court did not err in denying the petition. View "Hodges v. State" on Justia Law

After a jury trial, Defendant was convicted of multiple drug-related offenses. The court of appeals affirmed. Defendant subsequently filed a petition for postconviction relief, alleging that his trial counsel was ineffective for failing to impeach one of the state's witnesses, failing to object to comments made by the State in closing arguments, and failing to challenge the jury-selection process, among other reasons. The circuit court denied Appellant's petition without a hearing. The Supreme Court affirmed the denial of postconviction relief on all points, holding that the circuit court did not commit prejudicial error in denying postconviction relief. View "Bond v. State" on Justia Law

After a jury trial, Petitioner was convicted of rape and sentenced as a habitual offender to life imprisonment. Petitioner subsequently filed a pro se petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis. After the petition was denied, Petitioner filed another pro se petition seeking leave to have jurisdiction reinvested in the trial court to consider a coram-nobis petition. The Supreme Court dismissed the petition, holding that Petitioner's successive application for coram-nobis relief was an abuse of the writ in that Petitioner alleged no facts sufficient to distinguish his claim in the instant petition from the claim in the first. View "Rodgers v. State" on Justia Law

Defendant was fined in the district court for driving sixteen miles over the speed limit. On appeal, Defendant was convicted of speeding in excess of fifteen miles per hour over the speed limit. The court of appeals reversed and dismissed Defendant's conviction. Defendant subsequently filed a motion for award of costs on appeal under Ark. R. Sup. Ct. 6-7. The Supreme Court accepted certification from the court of appeals to determine whether the State may be liable for costs under Rule 6-7. The Supreme Court denied the motion for costs on appeal, holding that Defendant's claim against the State was barred by the doctrine of sovereign immunity. View "Kiesling-Daugherty v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was not afforded effective assistance of counsel at trial. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant's allegation that his trial counsel was ineffective for failing to call a witness during the penalty phase of his trial was conclusory and thus without merit; and (2) the trial court did not err in finding Defendant's claim that his attorney should have secured a change of venue was conclusory in nature and not supported by facts. View "James v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and sentenced to life imprisonment. Defendant subsequently filed a petition for postconviction relief, which was denied. Thereafter, Defendant filed a successive petition to correct an illegal sentence, arguing that his sentence was illegal because the State was allowed to amend the information to charge him with first-degree murder by premeditation and deliberation. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant's petition, as the sentenced imposed was within the sentencing range for the offense of first-degree murder. View "Hill v. State" on Justia Law

Appellant pleaded guilty to several drug offenses in 2006. The circuit court sentenced Defendant to thirty-six months' imprisonment along with eighty-four months' suspended imposition in sentence. In 2010, the State filed a petition to revoke Appellant's suspended sentence. Appellant pleaded no contest. The circuit court then revoked Appellant's suspended sentence and sentenced him to 168 months' imprisonment. Appellant subsequently filed a pro se petition to correct an illegal sentence, arguing that the circuit court's revocation order was beyond the statutory maximum to which he was originally exposed. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's sentence of 168 months' imprisonment upon revocation was within the statutory limits to which he was originally exposed. View "Walton v. State" on Justia Law

Defendant was charged with second-degree sexual assault of K.J., a person less than fourteen years old, who was Defendant's cousin. Prior to trial, Defendant filed a motion under Ark. Code Ann. 16-42-101(c), Arkansas's rape-shield statute, seeking to introduce at trial evidence of specific instances of sexual conduct of K.J. Specifically, Defendant sought to introduce a specific instance of sexual conduct that occurred between K.J. and her cousin, D.R., when K.J. was nine or ten years old. The circuit court granted the motion. The State brought this interlocutory appeal. The Supreme Court reversed, holding that the circuit court abused its discretion by ruling that the evidence was admissible, as the probative value of the testimony relating to K.J.'s statement to her mother about the alleged instance of sexual conduct was slight and was substantially outweighed by the prejudicial and inflammatory nature of the testimony. View "State v. Kindall" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. Appellant appealed, contending that the circuit court erred in denying her motion to suppress physical evidence seized from the living room and patio in her residence and in failing to grant her motion for a mistrial after her trial counsel's father died on the second day of trial. The Supreme Court affirmed, holding (1) any error resulting from the admission of evidence from the living room and patio was harmless; and (2) under the circumstances, the trial court did not abuse its discretion in denying Appellant's counsel's motion for a mistrial due to the death of trial counsel's father. View "Livingston v. State" on Justia Law