Justia Constitutional Law Opinion Summaries

Appellant pleaded guilty to terroristic threatening in the first degree and was placed on five years' supervised probation. Because Appellant violated the conditions of his probation, his probation was revoked and he was sentenced to five years' imprisonment. Counsel for Appellant subsequently filed a petition for writ of error coram nobis, asserting that Appellant was mentally incompetent when he pleaded guilty and, therefore, the finding of guilt should be set aside. The trial court denied the petition. The Supreme Court dismissed the appeal and declared the motion related to the appeal moot, holding that because Petitioner had served his sentence by the time he filed this petition, his claim was moot, and a new revocation proceeding would not be an appropriate remedy. View "Hayden v. State" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life in prison. Defendant appealed, arguing that the circuit court erred in denying his motion to suppress incriminating statements he made to police officers after he invoked his right to remain silent. The Supreme Court ordered rebriefing due to deficiencies in the briefs filed by both the State and Defendant, finding (1) the State's brief failed to comply with the requirement of Ark. R. Crim. P. 4-3(i) because the State did not brief "all points argued by the appellant"; and (2) Defendant's brief was deficient because it failed to include necessary materials in the addendum. View "Fritts v. State" on Justia Law

After a jury trial, Petitioner was convicted of kidnapping and rape. The Supreme Court affirmed. Petitioner subsequently filed two pro se petitions seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis, contending (1) he was denied a fair trial because the victim's stepfather was related to the jury foreman, (2) two of the State's witnesses recanted their testimony after trial, (3) his appellate attorney filed a "no merit" brief pursuant to Anders v. California, (4) the prosecution withheld evidence favorable to the accused, and (5) the county circuit court in which he was tried did not have jurisdiction over his rape charge. The Supreme Court denied the petitions, holding (1) Defendant's first claim was not cognizable as a ground for a writ of error coram nobis; (2) recanted testimony in itself is not a ground for issuance of the writ; (3) Petitioner failed to show the filing of an Anders brief presented an issue that fits within the purview of a coram-nobis proceeding; (4) Petitioner failed to establish a Brady violation occurred; and (5) the circuit court had jurisdiction to try Petitioner. View "Cromeans v. State" on Justia Law

After a jury trial, Defendant was found guilty of aggravated residential burglary, two counts of aggravated robbery, and battery in the first degree. An order was later entered relieving Petitioner's retained attorney of any further responsibility as counsel for Petitioner. Petitioner subsequently filed a motion to proceed with a belated appeal from the judgment, stating that, once counsel was relieved, Petitioner was left without an attorney to represent him on direct appeal and that no steps were taken to ensure that his right to appeal was protected. The Supreme Court denied the motion, holding that Petitioner failed to meet his burden of establishing that there was good cause for his failure to timely appeal. View "Williams v. State" on Justia Law

After a jury trial, Petitioner was convicted of murder in the first degree and sentenced as a habitual offender to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner subsequently filed a verified pro se petition for postconviction relief, claiming that his ability to represent himself at trial acting pro se was compromised by the prosecution and his stand-by counsel and that his attorney on direct appeal was ineffective. The trial court denied the petition. No appeal was taken, and Petitioner sought leave to proceed with a belated appeal of the order. The Supreme Court denied the motion, holding (1) Petitioner's allegations regarding his first claim did not merit postconviction relief; and (2) Petitioner failed to show that he was prejudiced by his attorney's assistance on direct appeal. View "Walton v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a complaint against certain ADC authorities in their official capacities, seeking injunctive relief and damages against Appellees for their refusal to restore Appellant's Class I-B inmate status, which Appellant enjoyed while incarcerated in the county jail. Appellant also challenged Appellees' refusal to secure and provide to Appellant the privileges of Class I-B inmate status and their refusal to allow Appellant's participation in the prison's hobby-craft program. The circuit court dismissed the action with prejudice. The Supreme Court affirmed, holding that Appellant's complaint was barred by sovereign immunity and failed to state a claim upon which relief could be granted. View "Smith v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to 1080 months' imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se verified petition for postconviction relief, contending that he was not afforded effective assistance of counsel and that there were a number of errors in his trial. The circuit court denied the petition. Appellant appealed and filed a motion for extension of time to file his brief-in-chief. The Supreme Court dismissed Appellant's appeal and declared his motion moot, holding (1) Appellant did not provide any factual substantiation for his conclusory claims that counsel was ineffective; and (2) Appellant's claims of trial error did not state a basis for granting a postconviction relief petition. View "Nickelson v. State" on Justia Law

After Appellant submitted a petition for nomination for city director, the city clerk informed Appellant that her petition did not meet the statutory requirement of having fifty qualified electors. Appellant subsequently filed a petition for writ of mandamus and injunctive relief, requesting that the clerk be compelled to certify her as a candidate for the city director position and that an injunction issue to prevent the election board from taking any action that would affect her right to be considered as a candidate. The circuit court denied Appellant's petition and ordered the election commission to remove her name from the November 2012 election ballot. The Supreme Court dismissed Appellant's appeal as moot because the election had already been held and the Court was not persuaded that an exception should be made in this case. View "Lott v. Langley" on Justia Law

After a trial, Appellant was convicted of unspecified offenses. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging numerous claims. The trial court denied the petition, finding Appellant's claims were not diligently filed, that alleged due process violations were not grounds for the writ, and that Appellant was competent at the time of the offense and competent to stand trial. The Supreme Court dismissed Appellant's appeal and declared his motion to have copies of his brief-in-chief duplicated at public expense moot, holding that, because two of the issues raised by Appellant were not cognizable in a proceeding for a writ of error coram nobis, and because Appellant failed to produce a sufficient record on which to consider his other claims, Appellant could not prevail on appeal. View "Greene v. State" on Justia Law

After a trial, Appellant was convicted of possession of a controlled substance, possession of drug paraphernalia, maintaining a drug premises, and simultaneous possession of drugs and firearms, for which he was sentenced to twenty-nine years' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging, among other claims, that he was denied his Sixth Amendment right to counsel of his choice. Appellant had requested a change of counsel on the eve of trial, and the circuit court denied the request despite the fact that Appellant had already obtained substitute counsel. The circuit court denied Appellant's petition for postconviction relief. The Supreme Court reversed, holding that the circuit court wrongly denied Appellant's motion to substitute new counsel because the court failed to consider Appellant's interests when deciding the motion. Remanded for a new trial. View "Arroyo v. State" on Justia Law