Williams v. Hobbs; Jones, Jr. v. Hobbs, No. 10-1573 (8th Cir. 2011)
Annotate this CaseSeveral Arkansas prisoners on death row challenged the state's Method of Execution Act under 42 U.S.C. 1983, arguing that it violated the ex post facto clause and their due process right to access the courts. The court held that the district court properly dismissed the section 1983 claim based on violation of the ex post facto clause. The court also held that the district court was correct to dismiss the section 1983 claim based on lack of access to the courts. The court further held that, while the court agreed that the district court erred in classifying a defendant's habeas petition as "second or successive" because he could not have raised his current claims at the time of his first petition, the dismissal of the petition was harmless error. The court finally held that the district court did not abuse its discretion in denying the Rule 59(e) motion.
Court Description: Civil Case - civil rights. Dismissal of challenge to Arkansas's Method of Execution Act as violating the ex post facto clause and due process right to access the court is affirmed. There is not an ex post facto claus violation because the possibility that the director could eliminate anesthesia does not create a significant risk of increased punishment, because there should not be an increased mental anxiety because information is available under FOIA (including the quantity, method, and order of administration), and because it is speculative that the protocol would have been more humane had the Act been subject to the APA. The due process claims fails because inability to discover potential claims is not a due process violation and no actual injury has been shown. District court did not abuse its discretion in declining to exercise supplemental jurisdiction in Williams's case. District court's classification of habeas claim as second or successive was harmless error. District court's denial of Rule 59(e) motion was not an abuse of discretion because the new evidence does not add anything concrete.
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