District Court, W.D. Arkansas — appointed by George H.W. Bush
Roberson v. Helder
District Court, W.D. Arkansas · 2011-06-08 · cited 1×
This case involved a federal habeas corpus petition under 28 U.S.C. § 2254 filed by a prisoner convicted in Fayetteville District Court of driving while intoxicated and driving left of center. The petitioner claimed that his attorney's failure to timely file the complete district court record prevented perfection of an appeal to circuit court, depriving him of a jury trial and amounting to ineffective assistance of counsel. The district court adopted the magistrate judge's recommendation, granted the petition, vacated the sentence, and remanded the matter to state district court for resentencing within 120 days or dismissal of the charges with prejudice. The core reasoning was that the attorney error was prejudicial under Strickland standards, the petitioner had exhausted available state remedies, and procedural gaps in Arkansas rules left no effective corrective process at the state level.
criminal lawprocedurecivil rights
Sasser v. Hobbs
District Court, W.D. Arkansas · 2010-11-03 · cited 2×
This case involves a federal habeas corpus petition under 28 U.S.C. § 2254 filed by Andrew Sasser, who was convicted of capital murder and sentenced to death in Arkansas for the 1993 killing of Jo Ann Kennedy. Sasser’s remaining claim asserted that he is mentally retarded and therefore ineligible for the death penalty. The court dismissed the claim with prejudice, finding that Sasser’s IQ scores did not fall at or below the Arkansas statutory cutoff of 70 and that evidence of his adaptive functioning did not establish mental retardation under applicable state law standards. The decision rested on the requirement that both subaverage intellectual functioning (IQ ≤ 70) and adaptive deficits must be shown, along with consideration of prior state precedents interpreting the relevant statute.
criminal lawprocedure
Chappell v. Helder
District Court, W.D. Arkansas · 2010-03-01 · cited 1×
In this case, pro se plaintiff Daniel Chappell, an inmate at the Washington County Detention Center, brought a 42 U.S.C. § 1983 action alleging that religious presentations conducted during mandatory lockout periods in the day room violated his First Amendment rights to free exercise of religion and against establishment of religion, and that restrictions on reading materials and lack of legal resources denied him meaningful access to the courts. The court adopted the magistrate judge's report and recommendation in full, entering judgment for the plaintiff on the religion claims with an award of $1 in nominal damages and $350 in costs, while denying the access-to-courts claim for lack of demonstrated actual injury to a nonfrivolous legal claim. The core reasoning was that the non-denominational presentations occurred three times a week in a confined space where inmates could not leave or easily avoid them, combined with a policy limiting inmates to only the Bible during early-morning lockouts, which impermissibly burdened free exercise and constituted an establishment of religion; by contrast, the court found the facility's policies on legal materials and attorney contact did not hinder the plaintiff's ability to pursue his case. The court ordered defendants to submit revised policies on religious presentations and reading materials by March 22, 2010.
religious libertycivil rightscriminal law
Betty's Homes, Inc. v. Cooper Homes, Inc.
District Court, W.D. Arkansas · 2009-08-27
This case involved a dispute over whether a $200,000 payment made by debtor Betty’s Homes to supplier Cooper Homes shortly before Betty’s bankruptcy filing could be avoided as a preferential transfer under 11 U.S.C. § 547. The bankruptcy court denied the avoidance claim, finding no evidence that Cooper received more than it would have in a Chapter 7 liquidation. On cross-appeal, the district court affirmed the result but held that the payment fell within the earmarking doctrine and was not an avoidable transfer because Cooper held inchoate materialman’s liens under Arkansas law that could be perfected post-petition and related back, making it a secured creditor equivalent to the bank that funded the payment. The court reasoned that the transfer therefore substituted one secured creditor for another without diminishing the bankruptcy estate.
business & regulatorypropertyprocedure
Teas v. Ferguson
District Court, W.D. Arkansas · 2009-03-19 · cited 2×
In Teas v. Ferguson, a pro se inmate brought a 42 U.S.C. § 1983 action against Benton County Detention Center officials alleging that excessive force was used against him on two occasions, that he was denied access to the courts due to lack of a law library, that the grievance procedure was inadequate, and that he was retaliated against for filing grievances. The district court adopted the magistrate judge's report and recommendation, granting summary judgment to dismiss the access-to-courts claim, the grievance-procedure claim, the retaliation claim, and all claims against Captain Hunter Petray and Sheriff Keith Ferguson for lack of supporting evidence of personal involvement or inadequate training. The court denied summary judgment on the two excessive-force claims, finding genuine issues of material fact, and exercised its discretion under Federal Rule of Civil Procedure 39(b) to grant the plaintiff's request for a jury trial on those claims, citing his explanation for the untimely demand and the suitability of credibility determinations for a jury without prejudice to defendants.
civil rightscriminal lawprocedure
Helm v. Sun Life Assur. Co. of Canada
District Court, W.D. Arkansas · 2008-11-24 · cited 1×
The case involves an ERISA appeal by Michael Helm, former President and CEO of Sparks Health System, challenging Sun Life Assurance Company of Canada's termination of his long-term disability benefits under an employee welfare benefit plan. The court applied an abuse-of-discretion standard of review, adjusted downward due to Sun Life's conflict of interest as both claims administrator and payer. It found that Sun Life breached its fiduciary duty by relying solely on one consultant's record review, despite contrary evidence from four examining or treating physicians and a substantial financial stake of up to $720,000 in denying benefits. The court therefore reversed the termination decision, awarded Helm $240,000 in past unpaid benefits, and ordered immediate reinstatement of benefits for as long as he remains eligible.
labor & employmenthealthcarebusiness & regulatory