Justia Constitutional Law Opinion Summaries

Appellant entered a negotiated plea of guilty to aggravated robbery and theft of property. Appellant's subsequent motion to vacated the judgment against him was denied. More than six years from the date of Appellant's guilty plea, Appellant filed a petition to correct an illegal sentence, challenging the application of the habitual-ofender enhancement to his sentence. The circuit court denied the petition. Appellant appealed but did not tender a timely brief-in-chief. Before the Supreme Court was Appellant's motion to file belated brief in this appeal. The Court dismissed the appeal and declared the motion moot, holding that Appellant could not prevail if his appeal were allowed to proceed, as the habitual-offender issue was not timely and Appellant's sentence was clearly within the prescribed statutory range. View "Redus v. State" on Justia Law

A judgment was entered reflecting that Appellant entered a plea of guilty to delivery of a controlled substance. Appellant was placed on probation for 120 months. An amended judgment-and-commitment order was entered seven days later. Later that year, a judgment-and-commitment order was entered reflecting that Appellant's probation had been revoked and that she had been sentenced to imprisonment. More than eight months after the original and amended judgments had been entered and four months after the order revoking probation had been entered, Appellant filed a pro se petition for postconviction relief. The petition was dismissed on the grounds that it was not timely filed and did not state a basis for postconviction relief. The Supreme Court dismissed Appellant's appeal and declared the motions related to the appeal moot, holding that Appellant's petition was untimely filed. View "Murphy v. State" on Justia Law

After a jury trial, Appellant was convicted of second-degree murder and possession of a firearm by certain persons. Appellant subsequently filed a pro se petition for postconviction relief. Circuit Judge Susan Hickey scheduled a hearing on the petition, but prior to the date of the hearing, Judge Hickey resigned her seat as judge. On November 21, 2011, Circuit Judge Hamilton Singleton denied Appellant's petition without a hearing. Appellant filed two motions for reconsideration, requesting the circuit court set aside its order and hold a hearing on the petition as originally scheduled by Judge Hickey. Appellant's first and second motions were denied. On March 28, 2012 Appellant filed a notice of appeal from the circuit court's order denying his petition for postconviction relief. The Supreme Court dismissed Appellant's appeal, holding that it was untimely in this case. View "Lovett v. State" on Justia Law

Appellant was an inmate in the Department of Correction serving a life sentence. Appellant filed a complaint against the governor, the chairman of the parole board, and the chairman of the board of correction seeking a declaratory judgment, injunctive relief against Defendants for civil-rights violations, and relief as a taxpayer for an illegal exaction based on claims concerning the procedures for submission of applications for clemency. The circuit court dismissed the complaint for failure to state a claim upon which relief may be granted. Appellant appealed and filed motions related to his appeal. The Supreme Court denied the motions and affirmed the circuit court's dismissal of the complaint, holding that the court did not abuse its discretion in concluding that Appellant failed to state a claim on the three bases that Appellant raised in this appeal. View "Holloway v. Beebe" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder and first-degree battery and failure to stop after an accident with injury or death. Appellant appealed, contending that the trial court erred by refusing to instruct the jury on the offense of felony manslaughter, which he argued was a lesser-included offense of felony murder. In so arguing, Appellant contended that although Perry v. State and Hill v. State supported the trial court's ruling, those cases ignored Ark. Code Ann. 5-2-203(b). The Supreme Court affirmed, holding (1) the Court would not accept Appellant's invitation to overrule Perry and Hill; and (2) the Court's felony-murder jurisprudence is in concert with the legislature's mandate stated in section 5-2-203(b). View "Holian v. State" on Justia Law

Petitioner was convicted of eleven counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The court imposed an aggregate sentence of 108 months' imprisonment. Petitioner did not appeal the sentencing order and subsequently sought leave to proceed with a belated appeal. In his motion, Petitioner asserted that his appointed attorney did not provide effective assistance of counsel and that the evidence was insufficient to sustain the judgment. The Supreme Court denied the motion, holding that Petitioner did not demonstrate good cause to permit him to proceed with a belated appeal, as Petitioner's allegation concerning his attorney's effectiveness at trial and his claim of actual innocence were not matters to be addressed in a proceeding for a belated appeal. View "Davis v. State" on Justia Law

Petitioner was convicted of three counts of rape and three counts of terroristic threatening. The convictions were affirmed on direct appeal. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecution withheld evidence of reports and transcripts of the victims' statements and that this was a violation of Brady v. Maryland. The Supreme Court denied the writ, holding that Petitioner did not establish a Brady violation because Petitioner's claim that the materials were not made available to his defense did not appear meritorious. View "Sparks v. State" on Justia Law

Appellant was convicted of rape and sentenced to 300 months' imprisonment. The Supreme Court affirmed Appellant's conviction and sentence, holding that the circuit court did not err in (1) denying Appellant's motion in limine to suppress statements he made to his psychotherapist and the medical records pertaining to his treatment, as the argument was not preserved for appellate review; and (2) granting the State's motion in limine to exclude any instance of abuse that might have occurred after the victim turned fourteen years old, as Appellant failed to preserve his argument that the evidence would have been relevant and admissible to impeach the victim's credibility. View "Riley v. State" on Justia Law

Petitioner was convicted of two counts of rape and sentenced to an aggregate sentence of 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel at trial. The Supreme Court denied the petition, holding that Petitioner's allegation was outside the purview of a coram-nobis proceeding, and to the extent that Petitioner may have intended his claims to be an attack on the sufficiency of the evidence or the credibility of witnesses, such issues were also not cognizable in coram-nobis proceedings. View "McDaniels v. State" on Justia Law

Appellant was convicted of delivery of a controlled substance and sentenced to an enhanced sentence of forty years' imprisonment and a fine. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief and, later, a motion to correct an illegal sentence. Both requests were denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus raising double-jeopardy claims. The circuit court denied the petition. Appellant appealed and filed with the Supreme Court a motion for extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant's claims were not cognizable in a petition for habeas corpus. View "Khabir v. Hobbs" on Justia Law