Justia Arkansas Supreme Court Opinion Summaries

In 2018, John Patrick Cullen pleaded nolo contendere to second-degree sexual assault and was sentenced to seventy-two months' imprisonment. He did not appeal his conviction or sentence. In 2021 and 2022, Cullen filed petitions for writ of error coram nobis and writ of habeas corpus in the Garland County Circuit Court, alleging his innocence based on new evidence. This evidence included statements from the victim, Kathi Brinkley, which Cullen claimed contained factual errors, and an admission from a second individual, Kati Knight, that she did not witness the assault. Cullen also argued that the affidavit supporting his arrest contained fabrications by Brinkley.The Garland County Circuit Court denied Cullen's petitions, finding that he had failed to state a cause of action upon which relief could be granted and had not asserted any grounds for which he could successfully pursue these claims. Cullen appealed this decision to the Supreme Court of Arkansas.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that Cullen's claim of actual innocence was not cognizable under current law and that his allegations regarding Knight's admissions had been abandoned on appeal. Therefore, the court held that the lower court did not abuse its discretion in denying Cullen's petition for writ of error coram nobis. Regarding the writ of habeas corpus, the court found that Cullen had failed to state a colorable claim under the relevant statute and had not alleged that his sentence was illegal or that the trial court lacked subject-matter jurisdiction. Furthermore, the court concluded that the lower court did not have personal jurisdiction to issue a writ even if Cullen had stated a legitimate ground for relief, as his second habeas petition was not filed in the correct jurisdiction. View "CULLEN v. STATE OF ARKANSAS" on Justia Law

The case involves Damien Echols, one of the "West Memphis Three," who was convicted for the murder of three eight-year-old boys in 1993. Echols, along with Jason Baldwin and Jessie Misskelley, were found guilty, with Echols receiving a death sentence. In 2011, Echols entered an Alford plea, maintaining his innocence but acknowledging the prosecution's evidence, and was released from prison. Echols sought further DNA testing of the evidence using new technology, arguing that it could potentially identify the true perpetrator(s) of the crime.Previously, the Crittenden County Circuit Court denied Echols's petition for additional DNA testing under Act 1780, ruling that the court lacked jurisdiction as Echols was not in State custody. The court interpreted Act 1780 as a form of habeas corpus relief, traditionally available only to those in State custody. Echols appealed this decision, arguing that the plain language of Act 1780 allows any person convicted of a crime to petition for additional DNA testing to demonstrate actual innocence, regardless of their custody status.The Supreme Court of Arkansas reversed and remanded the lower court's decision. The court found that the plain language of Act 1780 unambiguously permits "a person convicted of a crime" to petition for additional DNA testing to demonstrate actual innocence. The court held that the lower court had misinterpreted the plain language of Act 1780 by imposing a requirement that a petitioner must be in State custody to seek relief under the Act. The court concluded that Echols, as a person convicted of a crime, was entitled to seek relief under Act 1780, regardless of his custody status. View "ECHOLS v. STATE OF ARKANSAS" on Justia Law

In Arkansas, attorney Chris Corbitt and other plaintiffs sought to challenge the prohibition of firearms in courthouses. Corbitt had previously attempted to bring a firearm into the Pulaski County District Courthouse and the Juvenile Justice Complex, but was denied. He filed a complaint, which was dismissed by the circuit court and later affirmed by the Supreme Court of Arkansas. Despite this, Corbitt and other plaintiffs filed another complaint after encountering firearm restrictions in a different courthouse. This complaint was also dismissed.The circuit court ruled that Corbitt was not entitled to injunctive relief, declaratory judgment, or a writ of mandamus. The court also found that even if issue preclusion were not applicable, it would rule similarly to Judge Wright’s decision regarding the interpretation of Arkansas Code Annotated section 5-73-122. The court rejected the plaintiff’s argument, stating that it was based on a flawed premise that misread the plain meaning of the statute and ignored the importance of Amendment 80 to the Arkansas Constitution. The circuit court emphasized that Amendment 80 gives the Arkansas Supreme Court the power to regulate court procedure, including the discretion to determine when weapons should be allowed in courtrooms.The Supreme Court of Arkansas held that Corbitt was collaterally estopped from pursuing his claims due to the previous litigation, but the remaining plaintiffs could proceed. The court further held that attorneys, as officers of the court, are authorized by statute to possess handguns in courthouses. The court reversed the circuit court’s denial of the petition for a declaratory judgment as it pertains to the remaining plaintiffs and remanded for further proceedings consistent with this opinion. View "CORBITT v. PULASKI COUNTY CIRCUIT COURT" on Justia Law

The case revolves around the conviction of Leashebia Davis for capital murder. The incident occurred on May 4, 2020, when Elvis Kendal was shot and killed. Davis was charged with capital murder on July 1, 2020, and was later convicted by a Jefferson County Circuit Court jury on May 17, 2023. She was sentenced to life imprisonment without the possibility of parole. The case was based on the testimonies of multiple witnesses, including Natasha Gill, a cousin of the victim, who witnessed the shooting, and Roderick Breedlove and Michael Brazell, who were with Davis in the vehicle at the time of the incident. The testimonies varied, with Davis and Breedlove implicating Brazell as the shooter, while Brazell testified that Davis was the shooter.The Jefferson County Circuit Court found Davis guilty of capital murder. Davis appealed the decision, arguing that there was insufficient evidence to support her conviction and that the court erred in denying her motion for a new trial based on juror misconduct. The court denied her motion for a new trial, asserting that Davis failed to demonstrate that the juror in question engaged in misconduct.The Supreme Court of Arkansas affirmed the lower court's decision. The court found substantial evidence to support Davis's capital murder conviction, including the testimonies of witnesses and the video-surveillance footage. The court also held that Davis failed to prove that the juror engaged in misconduct, as there was no evidence that the juror was dishonest during the jury-selection process or had any relationship with Davis's defense attorney. The court concluded that the lower court did not abuse its discretion by denying Davis's motion for a new trial. View "Davis v. State" on Justia Law

Jessie Hill, a prisoner serving life imprisonment without parole for capital murder and an additional 720 months for first-degree murder, filed multiple pro se petitions for writ of habeas corpus. He claimed double jeopardy, violations of his right to due process, insufficient evidence supporting his convictions, and other obscure claims. The Jefferson County Circuit Court dismissed his petitions, noting that Hill's pleadings were often illegible and contained profane language. The court concluded that Hill failed to establish that he was being illegally detained.Hill had previously filed multiple petitions for postconviction relief, including four habeas corpus petitions, all of which were denied by the circuit court and affirmed on appeal. In his current appeal, Hill argued that his convictions violated the prohibition against double jeopardy, that the charging informations were defective and violated his right to due process, and that there was insufficient evidence to support his convictions.The Supreme Court of Arkansas affirmed the circuit court's decision, stating that Hill's claims did not challenge the legality of his sentences or the subject-matter jurisdiction of the trial courts that entered the judgments of conviction. The court noted that a habeas proceeding does not afford a petitioner an opportunity to retry his case and is not a substitute for raising an issue either at trial or on direct appeal. The court concluded that Hill's double-jeopardy claim failed to state a basis for habeas relief, and his sufficiency-of-the-evidence claims represented an abuse of the writ as he had raised these claims in his previous habeas petitions. View "Hill v. Payne" on Justia Law

Eddie Lee Patrick, Jr., a prisoner, appealed the denial of his pro se petition for a writ of habeas corpus by the Jefferson County Circuit Court. Patrick was convicted of rape and terroristic threatening in the first degree by a Jefferson County jury in 2003 and was sentenced to 480 months' imprisonment. His conviction was affirmed by the Arkansas Court of Appeals. Patrick's petition for habeas corpus relief was based on pretrial DNA testing that he claimed proved his innocence.The Jefferson County Circuit Court denied Patrick's petition, and he appealed to the Supreme Court of Arkansas. Patrick argued that the lower court erred in not granting him habeas relief because the DNA evidence established his actual innocence. He also claimed that because the lower court allowed him to proceed in forma pauperis (without payment of a fee), it essentially held that the writ should be issued.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that while the DNA report showed that Patrick's DNA was not present, the jury was aware of this evidence and still found him guilty. The court also noted that Patrick did not meet the requirements to state a prima facie claim under Act 1780, as he did not seek specific scientific testing of evidence that was not available at the time of trial nor allege the existence of new scientific methods to retest evidence that was available at the time of trial. The court concluded that Patrick's claim for habeas relief was merely a challenge to the sufficiency of the evidence supporting his conviction. The court also rejected Patrick's argument about proceeding in forma pauperis, stating that being allowed to file a petition without paying a fee does not equate to the issuance of the writ. View "Patrick v. Payne" on Justia Law

David Stewart, an inmate, appealed the denial of his pro se petition for a writ of habeas corpus. He argued that his conviction for two counts of sexual assault violated the prohibition against double jeopardy and that a condition of his incarceration, requiring him to complete the Reduction of Sexual Victimization Program (RSVP), made his sentencing order illegal. Stewart also filed a motion for default judgment, claiming that the respondent failed to respond to his petition.The Jefferson County Circuit Court found that the sentencing order was not illegal on its face and that Stewart was not entitled to a default judgment on his petition for the writ. The court noted that Stewart was originally charged with one count of rape and one count of sexual assault, indicating distinct impulses involved in each charge of sexual assault. The court also found that the RSVP requirement was often imposed as a condition of parole or suspended imposition of sentence (SIS), not incarceration.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that Stewart failed to demonstrate that the sentencing order was illegal on its face or that the trial court lacked jurisdiction to convict him of separate counts of second-degree sexual assault. The court also found that Stewart failed to show that the RSVP requirement and the no-contact order were part of his incarceration rather than his suspended sentence. Lastly, the court ruled that the circuit court did not err in denying Stewart's motion for a default judgment, as the Arkansas Rules of Civil Procedure do not apply to a postconviction habeas proceeding. View "Stewart v. Payne" on Justia Law

The case revolves around a dispute over a medical marijuana cultivation license issued by the Arkansas Medical Marijuana Commission to Bennett Scott “Storm” Nolan II. 2600 Holdings, LLC, an unsuccessful applicant for the same license, filed a lawsuit against the Commission and other state entities, alleging that Nolan's application did not meet the minimum merit selection criteria and that the Commission violated its own rules and the Arkansas Constitution in awarding the license to Nolan. Nolan was not initially named as a defendant or joined as a party in the lawsuit.The Pulaski County Circuit Court denied Nolan's multiple motions to join the lawsuit as an indispensable party under Rule 19(a) of the Arkansas Rules of Civil Procedure and granted summary judgment in favor of 2600 Holdings. The court ruled that the Commission had exceeded its discretion and violated the Arkansas Constitution and its own rules in awarding the license to Nolan.On appeal, the Supreme Court of Arkansas reversed the lower court's decision, finding that Nolan was indeed an indispensable party under Rule 19(a)(2). The court held that the lower court erred in not joining Nolan as an indispensable party to the litigation. As a result, the court vacated the order granting summary judgment to 2600 Holdings and remanded the case for further proceedings. The court did not address Nolan's remaining issues as they were deemed moot due to the reversal and remand. View "Nolan v. 2600 Holdings, LLC" on Justia Law

The case involves a group of appellants who allegedly purchased luxury vehicles with funds provided by Dilmurod Akramov, the owner of CBC and D&O Group. The appellants would then transfer the vehicle titles back to Akramov's D&O Group without receiving cash or equivalent in exchange. They would then claim a "trade-in credit" against the sales tax due on the purchase of a vehicle. The Arkansas Department of Finance and Administration (DFA) argued that these were not valid sales as required by Arkansas law and denied the sales-tax-refund claims.The appellants challenged the DFA's decision through the administrative review process, which affirmed the DFA's decision. The appellants then appealed to the Pulaski County Circuit Court for further review. The circuit court found that the appellants' attorney, Jason Stuart, was a necessary witness and therefore disqualified him from further representing the appellants. The court also held the appellants in contempt for failing to provide discovery per the court's order.The Supreme Court of Arkansas affirmed the circuit court's decision. The court held that the circuit court did not abuse its discretion in disqualifying Stuart. The court applied the three-prong test from Weigel v. Farmers Ins. Co., which requires that the attorney's testimony is material to the determination of the issues being litigated, the evidence is unobtainable elsewhere, and the testimony is or may be prejudicial to the testifying attorney’s client. The court found that all three prongs were satisfied in this case. The court also affirmed the circuit court's decision to strike the third amended and supplemental complaint filed by Stuart after his disqualification. View "STUART v. WALTHER" on Justia Law

The case revolves around Chris Corbitt, a holder of an Enhanced Concealed Carry License (ECCL), who filed a complaint for declaratory judgment and injunctive relief against Arkansas State University (ASU) and its trustees. Corbitt sought a declaration that he was entitled to enter the First National Bank Arena (FNB Arena), located on ASU's campus, with a firearm, except for areas hosting a collegiate sporting event. He also sought an order enjoining ASU from prohibiting ECCL holders from entering FNB Arena with a firearm. The FNB Arena is covered by an Alcoholic Beverage Control (ABC) permit, held by NEA Sports Club, which authorizes the consumption and sale of beer and wine on the premises during designated events.The Craighead County Circuit Court granted ASU's motion for summary judgment. The court found that under Arkansas law, FNB Arena can be covered by an ABC permit and ASU can lawfully prohibit firearms in FNB Arena to maintain the alcohol permit while complying with Ark. Code Ann. § 5-73-306(11)(B) as well as Title 3 permit requirements and ABC regulations.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that ASU can lawfully prohibit firearms at FNB Arena under section 5-73-306. The court reasoned that while universities do not have the discretion to prohibit firearms, ASU is prohibiting firearms at FNB Arena because the facility is covered by an alcohol permit, not because it is attempting to exercise discretion. The court concluded that the unambiguous language of subdivision (11)(B) supports ASU’s position that an ECCL holder may not enter FNB Arena with a firearm. View "CORBETT V. ARKANSAS STATE UNIVERSITY" on Justia Law