Justia Arkansas Supreme Court Opinion Summaries

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

The case involves the Arkansas Voter Integrity Initiative, Inc., and Conrad Reynolds (appellants) who filed a complaint against John Thurston, the Arkansas Secretary of State, the Arkansas State Board of Election Commissioners, and Election Systems and Software, LLC (appellees). The appellants claimed that the voting machines approved by the state did not comply with the Arkansas Code and the Help America Vote Act of 2002 (HAVA) because voters could not independently verify their selections on the ballot before casting their votes. They argued that the machines printed ballots with both bar codes and the voter's selections in English, but the vote tabulator only scanned the bar codes. Since most voters cannot read bar codes, the appellants claimed that voters were unable to verify their votes as required by state and federal law. They also alleged that the appellees committed an illegal exaction by using public funds for the purchase and maintenance of these machines and that Election Systems and Software, LLC violated the Arkansas Deceptive Trade Practices Act and committed fraud by claiming that its machines complied with state and federal law.The Pulaski County Circuit Court dismissed the appellants' complaint. The court found that the voting machines complied with the Arkansas Code and HAVA. The court also denied the appellants' motion for recusal and their motion for a new trial. The appellants appealed these decisions.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that the voting process complied with the Arkansas Code and HAVA. The court also found that the appellants failed to demonstrate evidence of bias or prejudice sufficient to warrant the recusal of the circuit court judge. Finally, the court found that the appellants were not deprived of their right to a jury trial and that the circuit court did not err by denying their motion for a new trial. View "ARKANSAS VOTER INTEGRITY INITIATIVE, INC., AND CONRAD REYNOLDS v. JOHN THURSTON, IN HIS OFFICIAL CAPACITY AS ARKANSAS SECRETARY OF STATE; THE ARKANSAS STATE BOARD OF ELECTION COMMISSIONERS, IN ITS OFFICIAL CAPACITY; AND ELECTION SYSTEMS AND SOFTWARE, LLC" on Justia Law

The Supreme Court of Arkansas ruled in favor of the county assessor and other similarly positioned defendants, affirming the lower court's dismissal of a lawsuit brought by Ronald and Mitzi Kimbrough. The plaintiffs, representing themselves and other similarly situated taxpayers, had argued that the county assessor's method of calculating property tax assessments for homeowners over 65 or who are disabled violated the Arkansas Constitution's Amendment 79. In their view, the amendment should freeze the assessment on a homeowner's principal residence at the time of purchase. However, the defendants argued that the plaintiffs had failed to exhaust their administrative remedies, as required by law, before taking the case to court.The Supreme Court agreed with the defendants, noting that the plaintiffs' complaint must be handled by the County Court according to the Arkansas Constitution due to its relation to county taxes. The Court held that the plaintiffs had failed to exhaust the necessary administrative remedies before bringing the case to court, which deprived the court of subject-matter jurisdiction. The Court dismissed the plaintiffs' arguments about the potential policy implications of its ruling, noting that public policy is declared by the General Assembly, not the courts. Thus, the Court affirmed the lower court's dismissal of the case and dismissed the defendants' cross-appeal as moot. View "KIMBROUGH V. GRIEVE" on Justia Law

The Supreme Court of Arkansas affirmed a lower court's decision dismissing Floyd Sagely's claim that Arkansas Code Annotated section 5-73-103, which prohibits a person who has been involuntarily committed to a mental institution from owning or possessing a firearm, is unconstitutional. Sagely was involuntarily committed to a mental health treatment facility in 2010, and in 2019, was charged with a misdemeanor for possessing a firearm in his car due to his previous commitment.Sagely argued that the statute violated both the Equal Protection Clause of the Fourteenth Amendment and the precedent set by the Supreme Court in New York State Rifle & Pistol Ass’n v. Bruen. He contended that the law treated felons and persons involuntarily committed to a mental health facility differently, as felons could petition to have their gun rights reinstated, while those who were involuntarily committed could not.The Supreme Court of Arkansas found that Sagely's equal protection claim failed because he could not demonstrate that he and persons convicted of a felony offense were similarly situated. The court stated that civil litigants like Sagely are not similarly situated to criminal defendants for equal-protection purposes. The court further held that the statute is presumptively constitutional under Supreme Court precedent. Therefore, the court affirmed the lower court's dismissal of Sagely's complaint. View "SAGELY v. HUTCHINSON" on Justia Law