Justia Constitutional Law Opinion Summaries

Mark Moore and two others filed suit against the Arkansas Secretary of State, challenging certain Arkansas statutes that set the filing deadline for individuals who wish to appear on the general election ballot as independent candidates. Plaintiffs sought a declaratory judgment that the filing deadline is unnecessarily early and thus violates the First and Fourteenth Amendments, as well as 42 U.S.C. 1983. Plaintiffs sought to enjoin the Secretary from enforcing this deadline against Moore. The district court granted the Secretary's motion for summary judgment and denied Moore's motion for reconsideration. The court concluded that the district court correctly noted that the March 1 filing deadline for independent candidates imposes a burden "of some substance" on Moore's First and Fourteenth Amendment rights and that Arkansas has a compelling interest in timely certifying independent candidates for inclusion on the general election ballot. The court concluded, however, that the district court erred in determining that there was no genuine dispute of material fact whether the March 1 deadline is narrowly drawn to serve that compelling interest. In this case, there exists a genuine factual dispute whether the verification of independent candidate petitions would conflict with the processing of other signature petitions under the former May 1 deadline. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings. View "Moore v. Martin" on Justia Law

Marcel Williams filed suit under 42 U.S.C. 1983, challenging the Arkansas lethal injection execution protocol. After the district court denied Williams' motion for a preliminary injunction, he moved for a stay of execution pending appeal. Williams' as-applied challenge alleged that due to his medical conditions, there was a substantial and unjustifiable risk that the execution method would cause him severe pain and serious harm in violation of the Eighth Amendment. The court concluded that Williams failed to offer evidence establishing a significant likelihood of success on the merits. In this case, the State produced testimony that the execution protocol would succeed despite Williams' health conditions; Williams failed to identify a known and available alternative method of execution that would substantially reduce a significant risk of pain; and Williams unreasonably delayed in bringing this as-applied challenge. Accordingly, the court denied the motion for a stay of execution pending appeal. View "Williams v. Kelley" on Justia Law

Marcel Williams, convicted of capital murder, kidnapping, rape, and aggravated robbery, moved for a stay of execution. Williams wanted to re-open the denial of federal habeas relief in 2009, renewing his claims of ineffective assistance of counsel at the guilt and penalty phases of his trial. The court concluded that Williams lacked a reasonable likelihood of success on his claims for Rule 60(b) relief based on ineffective assistance of counsel during either the penalty phase or the guilt phase of his trial. Therefore, Williams was not entitled to an extraordinary stay of execution. View "Williams v. Kelley" on Justia Law

Jack Harold Jones, Jr. appealed the district court's denial of a preliminary injunction, and moved for a stay of execution. Jones argued that, because of his specific medical conditions, the administration of the ADC's lethal-injection protocol will inflict cruel and unusual punishment on him in violation of the Eighth Amendment. The court concluded that Jones's delay in bringing his as-applied claim was sufficient reason to deny a stay; Jones failed to establish a significant possibility that he could show that, as applied to him, the State's lethal injection protocol creates a demonstrated risk of severe pain; and Jones failed to establish that there was a significant possibility that he could identify an alternative method of execution that is feasible, readily implemented, and in fact significantly reduces a substantial risk of severe pain. Therefore, the court affirmed the district court's order and denied a stay of execution. View "Jones, Jr. v. Kelley" on Justia Law

Two appeals were filed before this court five hours before Ledell Lee's scheduled execution. Lee challenged the district court's alleged denial of his motion requesting funds under 18 U.S.C. 3599(f) for "ancillary services to assist in the preparation of clemency and potential additional litigation." The court denied Lee's motion for stay of execution, concluding that Lee has failed to make a showing that there is a significant possibility that he will succeed on the merits of a claim that would deprive Arkansas of the authority to execute him. The court explained that, even if he succeeded on his section 3599(f) claim, Arkansas would still have the authority to execute him. View "Lee v. Kelley" on Justia Law

Four Arkansas death-row inmates appealed the denial of their motions for a preliminary injunction prohibiting their executions and moved the court for a stay of execution. The court concluded that, to the extent the inmates argued that Arkansas law, regulations, and policy during the clemency process violated the Due Process Clause of the Fourteenth Amendment, this argument failed under well-established law; even if the inmates are correct that the Board failed to comply with Arkansas law, regulations, and policy, this in and of itself is insufficient to demonstrate a significant possibility of success on the merits; the district court was correct in determining that, despite the procedural shortcomings in the clemency process, the inmates received the minimal due process guaranteed by the Fourteenth Amendment; and the court rejected the inmates' claim that the district court abused its discretion in determining that their procedural impossibility claim "evaporated" at the moment the Board recommended against granting clemency. Accordingly, because the inmates have failed to show a significant possibility of success on the merits, the court denied the motion for a stay. View "Lee v. Hutchinson" on Justia Law

The district court entered stays of execution in an action brought by nine Arkansas prisoners under 42 U.S.C. 1983. The prisoners were all convicted of murder and sentenced to death. The court granted the State's motion to vacate the stays, concluding that the prisoners could have brought their section 1983 method-of-execution claim much earlier and intentionally declined to do so; the district court's conclusion concerning the use of midazolam in the Arkansas execution protocol did not apply the governing standard; the district court's factual findings would not support a conclusion that the prisoners have a likelihood of success in showing that the execution protocol is sure or very likely to cause severe pain; the court disagreed with the legal standard that the district court applied in determining whether alternative methods of execution are known and available; and, even assuming a risk of pain from the current method, the availability of the several methods cited by the district court is too uncertain to satisfy the rigorous standard under the Eighth Amendment. Accordingly, the court vacated the stays of execution. View "McGehee v. Hutchinson" on Justia Law

Petitioner plead guilty to conspiring to distribute more than 1,000 kilograms of marijuana and possessing with intent to distribute more than 100 kilograms of marijuana. Petitioner sought habeas relief under 28 U.S.C. 2255 based on ineffective assistance of counsel. The district court denied the petition without an evidentiary hearing and this court granted a certificate of appealability (COA). The court concluded that petitioner failed to show a substantial likelihood that he would have accepted the offer to plead guilty pursuant to the more favorable terms offered prior to the suppression hearing. Consequently, petitioner has not proven that counsel's advice prejudiced his defense. The court also concluded that the district court did not abuse its discretion by denying petitioner's section 2255 petition without an evidentiary hearing. Accordingly, the court affirmed the judgment. View "Allen v. United States" on Justia Law

Petitioner, convicted of first degree murder, armed criminal action, and first-degree assault, appealed the district court's denial of his 28 U.S.C. 2254 petition for habeas relief. Petitioner argued that the State failed to disclose that a key prosecution witness received favorable consideration in exchange for his testimony. The court noted that, even if it had reason to doubt compliance with the statute of limitations in this case, the court proceeded to the merits in the interest of judicial economy. On the merits, the court concluded that the State did not violate Brady v. Maryland nor Napue v. Illinois where nothing in the factual findings indicated that the district court's finding that no formal or tacit agreement existed between the State and the witness was reasonable. The court assumed that the financial assistance the witness received for staying in a hotel for one week and relocating to another apartment was subject to Brady's disclosure mandate. However, failure to disclose this information here did not violate Brady because it did not undermine confidence in the verdict. Accordingly, the court affirmed the denial of habeas relief. View "White v. Steele" on Justia Law

After plaintiff was injured as a delivery driver for UPS and UPS failed to offer him another full time position that he was able to perform, plaintiff filed suit for disability discrimination and retaliation. The district court granted summary judgment to UPS. The court concluded that the district court correctly concluded as a matter of law that plaintiff was not qualified to perform the essential job functions for the delivery driver position; however, the district court erred by determining as a matter of law that defendant was unable to perform the essential job functions of the feeder driver position; there was sufficient evidence to create a genuine issue of material fact on his claim that he was qualified to perform the essential functions of the position; plaintiff presented evidence that UPS expected that feeder driver positions would become open in the near future; and thus defendant provided sufficient evidence to support his 2012 disability discrimination claim. In regard to the 2013 discrimination claim, plaintiff failed to offer sufficient evidence that he was qualified to perform the essential job functions of any available job; plaintiff failed to show that UPS failed to make a good faith effort to help him in seeking an accommodation; and thus summary judgment for UPS was appropriate as to this claim. Finally, the court concluded that defendant waived his 2013 accommodation claim. Accordingly, the court affirmed in part, reversed in part, and remanded. View "Faidley v. United Parcel Service" on Justia Law