Justia Constitutional Law Opinion Summaries

After a jury trial, Petitioner was found guilty of attempted first-degree murder and first-degree battery. Petitioner subsequently filed a timely pro se petition for postconviction relief, which the trial court denied. Petitioner did not timely file a notice of appeal from the order and sought leave to proceed with a belated appeal. The Supreme Court granted the motion, holding that Petitioner established good cause for his failure to file a timely notice of appeal, as nothing in the record suggested that Petition was properly notified that the order denying his postconviction relief petition had been entered, and because the record was silent, the Court must assume that Petitioner was not properly notified. View "Robinson v. State" on Justia Law

A disciplinary action was imposed upon Appellant, an inmate of the Arkansas Department of Correction (ADC). Appellant filed a petition for judicial review and declaratory judgment seeking to challenge the dismissal of his grievance concerning the disciplinary action, the application of an administrative directive by prison officials, and policies he asserted were in violation of contractual obligations of the ADC concerning his conduct in regard to hobby crafts while incarcerated. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court correctly determined that Appellant's petition did not set forth facts to show deprivation of a liberty interest and, as a result, Appellant failed to sustain a claim under the Arkansas Administrative Review Act to support a judicial review of the ADC's decision. View "Renfro v. Smith" on Justia Law

Appellant was charged with capital murder and subsequently entered a negotiated plea of guilty to first-degree murder and received a sentence of 420 months' imprisonment. Appellant filed a timely pro se petition for postconviction relief, setting forth three claims for relief, each asserting that his trial counsel was ineffective. The trial court denied the petition without a hearing. The Supreme Court affirmed the order, holding that it was clear from the face of the petition that the allegations in the petition were without merit, as Appellant failed to allege any facts to support a demonstration of prejudice concerning his claims. View "Pennington v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and sexual abuse and sentenced to an aggregate term of life imprisonment. The Supreme Court affirmed. More than seventeen years after he was convicted of the offenses, Appellant filed a pro se motion for a new trial, contending, among other things, that the evidence at his trial was insufficient to sustain the verdict. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding (1) the motion for a new trial raised issues that could have been settled at trial or in a timely petition for postconviction relief; and (2) as such, Appellant could not prevail on appeal. View "Mills v. State" on Justia Law

Appellant was convicted of capital murder and aggravated robbery and sentenced to death and life imprisonment. The circuit court denied Appellant's subsequent motion for postconviction relief that alleged ineffective assistance of counsel. Appellant appealed and filed a motion for reconsideration. The circuit court denied the motion without an evidentiary hearing, concluding that Appellant was not entitled to relief on his claim that counsel was ineffective for failing to call a psychologist to testify as to Defendant's chronic substance abuse. The Supreme Court reversed and remanded for an evidentiary hearing, holding that the circuit court erred in failing to hold an evidentiary hearing, as the record did not conclusively show that Petitioner was not entitled to relief. View "Lacy v. State" on Justia Law

Petitioner was found guilty of sexual assault in the second degree and rape and was sentenced to an aggregate term of 720 months' imprisonment. Twenty-one months after the court of appeals issued a mandate affirming the convictions and sentences, Petitioner filed a pro se request for relief that the trial court treated as a petition for postconviction relief. The court dismissed the petition as untimely. Before the Supreme Court was Petitioner's motion for rule on clerk, seeking leave to lodge the record belatedly and proceed with an appeal. The Court denied the motion, holding that because the petition before the trial court was not timely filed, the trial court had no jurisdiction to grant the relief sought, and therefore, the appellate court also lacked jurisdiction. View "Holliday v. State" on Justia Law

Petitioner, proceeding pro se, sought a writ of mandamus and other relief on claims that Circuit Judge David Reynolds had failed to act promptly on pro se pleadings in two criminal cases filed against Petitioner. The Supreme Court requested an amended response on Petitioner's claims concerning the disposition of certain pro se pleadings in one of the cases. In that case, the Supreme Court had originally affirmed the judgment of conviction and reversed and remanded, ordering resentencing. However, the resentencing order was invalid. In response to the Supreme Court's request for an amended response, Judge Reynolds submitted a response to which he attached an amended sentencing order. Because the documentation reflected that a new resentencing order had been entered in the case, the judgment in the case was final, and any underlying motions, including Petitioner's pro se pleadings that were the remaining subject of his mandamus petition at issue, effectively received a disposition. Therefore, Petitioner's request for mandamus relief in regard to those claims was moot. View "Glaze v. Reynolds" on Justia Law

The Arkansas Department of Community Correction (DCC) owned a prison complex in Jefferson County that was part of several tracts of state land annexed to the City of Pine Bluff in 1999. The property was automatically zoned as residential. In 2011, DCC, with the approval of the Board of Correction, decided to use three existing buildings on its property to house persons who had been granted parole. The City objected to DCC's adding transitional housing to its prison complex. The circuit court granted declaratory judgment and injunctive relief in favor of the City, concluding that Ark. Code Ann. 16-93-1603 acted as a waiver of sovereign immunity and that DCC was subject to the zoning laws of the City. The Supreme Court reversed, holding that the circuit court erred in concluding that the General Assembly intended to waive the State's sovereign immunity in section 16-93-1603, and therefore, the circuit court lacked jurisdiction to hear the City's petition pursuant to the doctrine of sovereign immunity. View "Ark. Dep't of Cmty. Corr. v. City of Pine Bluff" on Justia Law

In 1999, Appellant was convicted of multiple felony-drug charges and sentenced to an aggregate life sentence. In 2012, Appellant filed a motion to vacate a void judgment. The circuit court denied the motion, determining that it did not have jurisdiction to consider the motion because the motion was an untimely petition under Ark. R. Crim. P. 37.1. Appellant appealed, asserting that the circuit court did have jurisdiction to consider his claim because he challenged the court's jurisdiction and a challenge to the court's jurisdiction can be raised as a matter of common law without regard to jurisdiction conferred by any statute or rule. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding that Appellant failed to establish that the circuit court had jurisdiction to consider his motion to vacate. View "Watts v. State" on Justia Law

In 1996, Appellant pled guilty to multiple felony offenses. An aggregate sentence of 720 months' imprisonment was imposed. In 2012, Appellant filed a pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. The trial court denied the petition, holding that the petition amounted to an untimely petition for postconviction relief under Ark. R. Crim. P. 37.1. Appellant appealed and filed two motions related to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that whether the petition was one under Rule 37.1 or under the statute, it was not timely filed, and the trial court did not therefore err in denying it. View "Purifoy v. State" on Justia Law