Justia Arkansas Supreme Court Opinion Summaries

Petitioners Jennifer McGill and Cherokee Nation Entertainment, LLC challenged the sufficiency of a proposed constitutional amendment regarding the Pope County casino license. They alleged that the Arkansas Secretary of State, John Thurston, improperly certified the amendment for the ballot. The petitioners claimed that the number of valid signatures was insufficient and that the popular name and ballot title were inadequate. Local Voters in Charge (LVC), the sponsor of the amendment, and Jim Knight intervened in the case.The Arkansas Supreme Court had previously granted expedited consideration and bifurcated the proceedings into two counts. For Count I, the court appointed a special master to resolve factual disputes about the number of valid signatures. The special master found that LVC had properly certified that no paid canvasser had disqualifying offenses and that LVC did not violate the pay-per-signature ban. The special master disqualified some signatures but concluded that LVC still had enough valid signatures to meet the requirement.The Arkansas Supreme Court reviewed the special master’s findings and determined that LVC complied with the statutory requirements for certifying paid canvassers. The court also found that the petitioners did not provide sufficient evidence to prove that LVC violated the pay-per-signature ban. As a result, the court denied the petition on Count I, allowing the proposed amendment to remain on the ballot. The court’s decision was based on the lack of clear error in the special master’s findings and the petitioners' failure to meet their burden of proof. View "McGill v. Thurston" on Justia Law

The case involves a class action against Progressive Northwestern Insurance Company, which allegedly violated Arkansas insurance law through a uniform adjustment practice. The named plaintiff, Misty Huddleston, claims that Progressive improperly reduced medical expense insurance coverage (Med-Pay) benefits by considering payments from secondary health-care insurance. This practice, documented as "Code 563," adjusts Med-Pay benefits based on amounts paid or anticipated to be paid by the insured’s health-care provider, rather than the actual billed amount.The Pope County Circuit Court certified the class, which includes all Arkansas residents who had Med-Pay claims adjusted by Progressive using Code 563 and received less than the policy limit for their claims between February 16, 2017, and September 28, 2023. Progressive appealed the certification, arguing that the claims were not common to the class, did not predominate over individual issues, Huddleston was not typical of the class, and a class action was not a superior method for handling the claims.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s decision. The court found that the commonality requirement was met because the core issue—whether Progressive’s adjustment practice was lawful—applied uniformly to all class members. The court also determined that common questions predominated over individual issues, as the legality of the adjustment practice was central to the case. Huddleston’s claims were deemed typical of the class because they arose from the same conduct by Progressive. Finally, the court held that a class action was the superior method for adjudicating the claims, as it would avoid repetitive litigation and ensure consistent adjudications. View "PROGRESSIVE NORTHWESTERN INSURANCE COMPANY v. HUDDLESTON" on Justia Law

In 2017, a jury in Pope County convicted Tyler Joseph Barefield of two counts of capital murder for the premeditated killings of Aaron Brock and Beau Dewitt. Barefield was sentenced to life without parole for each count and received an additional 180-month term for using a firearm in the commission of the murders. The murders occurred after Barefield, suspecting trespassers at his salvage yard, lay in wait with a rifle and ambushed Brock and Dewitt. Their bodies were later found crushed in vehicles at the salvage yard. Barefield's convictions were affirmed on direct appeal.Barefield subsequently filed a petition for postconviction relief under Rule 37 of the Arkansas Rules of Criminal Procedure, alleging ineffective assistance of counsel. The Pope County Circuit Court denied the petition, adopting the State’s proposed findings of fact and conclusions of law. Barefield appealed this decision, arguing that his trial counsel’s performance was deficient and prejudicial.The Supreme Court of Arkansas reviewed the case and applied the two-step analysis from Strickland v. Washington, which requires showing that counsel’s performance was deficient and that the deficiency prejudiced the defense. The court found that Barefield’s claims were unsubstantiated and conclusory. It held that decisions regarding trial strategy, such as not consulting a ballistics expert or not seeking a mistrial for prosecutorial statements, fell within the realm of reasonable professional judgment. The court also upheld the circuit court’s decision to exclude Colonel Arthur Alphin’s testimony on the victims’ cause of death, as Alphin was not a qualified medical expert.The Supreme Court of Arkansas affirmed the Pope County Circuit Court’s denial of postconviction relief, finding no clear error in its judgment. View "BAREFIELD v. STATE OF ARKANSAS" on Justia Law

Sir Jeffery McNeil-Lewis was convicted of first-degree murder, first-degree battery, eight counts of terroristic threatening, and firearm enhancements, resulting in a life sentence plus fifteen years. The convictions stemmed from a shooting at an abandoned house in West Memphis, where McNeil-Lewis and an accomplice fired at Jarvis Moore and Stacy Abram. Moore died, and Abram survived, identifying McNeil-Lewis as a shooter. Additional evidence, including eyewitness testimony and gunshot residue, linked McNeil-Lewis to the crime.The Crittenden County Circuit Court denied McNeil-Lewis's petition for postconviction relief under Rule 37, which claimed ineffective assistance of counsel. The court found that McNeil-Lewis failed to prove both deficient performance by his counsel and resulting prejudice. Specific claims included strategic decisions not to object to 911 calls on hearsay grounds, not to pursue self-defense, and not to object during sentencing. The court also found no prejudice from the failure to suppress evidence or from juror misconduct, as no actual bias was shown. Additionally, the court ruled that a Batson challenge would have been meritless and that not calling witnesses during sentencing was a strategic decision. Lastly, the court credited defense counsel's testimony that McNeil-Lewis was informed of and rejected a plea offer.The Arkansas Supreme Court affirmed the circuit court's judgment, finding no clear error in its conclusions. The court held that McNeil-Lewis's arguments on appeal did not adequately address the circuit court's findings, particularly regarding strategic decisions and lack of prejudice. The court also upheld the circuit court's credibility determinations and strategic decisions made by defense counsel, concluding that McNeil-Lewis failed to meet the burden of proving ineffective assistance of counsel. View "MCNEIL-LEWIS v. STATE OF ARKANSAS" on Justia Law

Christopher Segerstrom was convicted of capital murder for the 1986 killing of a four-year-old and was initially sentenced to life imprisonment without parole. He was 15 years old at the time of the crime. Following the U.S. Supreme Court's decision in Miller v. Alabama, which prohibits mandatory life without parole for juvenile offenders, Segerstrom's sentence was vacated and remanded for resentencing. The Washington County Circuit Court resentenced him to life with the possibility of parole after thirty years without a hearing, which was reversed by the Arkansas Supreme Court, mandating a hearing to consider mitigating factors.Upon remand, Segerstrom's fitness to proceed was contested. The circuit court initially found him unfit due to schizophrenia but later deemed him fit after a year of treatment, based on a forensic evaluation by Dr. Melissa Wright. Segerstrom's defense presented conflicting expert testimony, but the court credited Dr. Wright's findings. On the day of the resentencing hearing, Segerstrom's counsel requested a continuance, claiming he was unresponsive due to medication, which the court denied.During the resentencing, the court admitted prior testimony from Dr. Joseph Halka, who performed the autopsy, over Segerstrom's objection. The court also rejected a nonmodel jury instruction proposed by Segerstrom, which emphasized the differences between juvenile and adult offenders as per Miller. The jury ultimately sentenced Segerstrom to life imprisonment.The Arkansas Supreme Court affirmed the circuit court's decisions, holding that substantial evidence supported the finding of Segerstrom's fitness to proceed, the denial of the continuance was not an abuse of discretion, the admission of Dr. Halka's testimony was proper, and the rejection of the proposed jury instruction was appropriate given the sentencing options. View "SEGERSTROM V. STATE OF ARKANSAS" on Justia Law

Bobby Wyles was convicted of two counts of capital murder for killing Susie Fuller and Jerry Drinkwater in the presence of two children. The incident occurred on January 5, 2019, at the victims' home, where Wyles, Fuller, and Drinkwater were using drugs. An argument ensued, leading Wyles to stab Fuller and Drinkwater multiple times, resulting in their deaths. Fuller was stabbed thirty-two times, and Drinkwater twenty-eight times. Wyles claimed he was in a blacked-out state of rage due to drug use and alleged sexual assault by Drinkwater. Eyewitness testimony and DNA evidence supported the prosecution's case.The Perry County Circuit Court denied Wyles's motions for a directed verdict, and a jury found him guilty of capital murder. Wyles was sentenced to two consecutive life sentences without parole, plus two five-year sentences for the presence-of-a-child enhancements. Wyles appealed, arguing that he lacked the culpable mental state for capital or first-degree murder.The Arkansas Supreme Court reviewed the case, focusing on whether substantial evidence supported the capital murder convictions. The court noted that premeditation and deliberation could be inferred from the circumstances, such as the nature and extent of the wounds and the conduct of the accused. The court found that the evidence, including the number and nature of the stab wounds and the prolonged struggle, supported the jury's conclusion of premeditation and deliberation. The court affirmed the circuit court's denial of Wyles's directed-verdict motion and upheld the capital murder convictions. The court also reviewed the record for any prejudicial errors and found none. The Arkansas Supreme Court affirmed the convictions and sentences. View "Wyles v. State" on Justia Law

Petitioners Lauren Cowles and Arkansans for Limited Government (AFLG) filed an original action against John Thurston, Arkansas Secretary of State, after the Secretary rejected their petition for the Arkansas Abortion Amendment of 2024. AFLG sought the court's intervention to overturn the Secretary's decision, vacate the insufficiency determination, and order the Secretary to count all submitted signatures.The Secretary argued that the court lacked jurisdiction, claiming the rejection was for "want of initiation" rather than insufficiency. The Arkansas Supreme Court disagreed, asserting jurisdiction under the Arkansas Constitution. The court denied the Secretary's motion to dismiss.The core issue was AFLG's failure to comply with statutory requirements for paid canvassers. AFLG admitted it did not submit the required paid canvasser training certification with the petition. The court held that this failure was fatal to the petition's validity. The court ordered the Secretary to count signatures collected by volunteer canvassers but upheld the rejection of signatures collected by paid canvassers due to the missing certification.The Arkansas Supreme Court concluded that AFLG did not meet the required number of valid signatures to proceed. The court denied further relief to AFLG, affirming the Secretary's decision to reject the petition based on the statutory non-compliance. The petition was granted in part and denied in part, with the mandate to issue immediately. View "COWLES V. THURSTON" on Justia Law

The case revolves around a dispute over the constitutionality of two Arkansas statutes that mandate the creation of certain county-funded employee positions to serve three of the seventeen judicial-district divisions within the Sixth Judicial Circuit serving Pulaski and Perry Counties. The funding for these positions was initially part of the 2023 budget, authorized by Pulaski County Ordinance No. 22-OR-45. However, Pulaski County Judge Barry Hyde later announced his decision not to fill some of the vacant positions within the Fifth Division. This led to a lawsuit by then-sitting Fifth Division Circuit Judge Wendell Griffen and his successor in office, Judge-elect LaTonya Austin Honorable, against Judge Hyde, seeking a judicial remedy to mandate the filling of these positions as appropriated in the 2023 budget.The case was first heard in the Pulaski County Circuit Court, where Judge Hyde contended that the two statutes in question are unconstitutional as special and local legislation under amendment 14 of the Arkansas Constitution. The circuit court ruled in favor of Judge Hyde, declaring the statutes unconstitutional because they apply only to specific divisions rather than all divisions in the Sixth Judicial Circuit. The court also dismissed arguments of estoppel raised by Judge-elect Honorable, finding that Pulaski County’s previous funding of these positions did not preclude it from now challenging the constitutionality of the statutes.Upon appeal, the Supreme Court of Arkansas affirmed the lower court's decision. The Supreme Court held that both statutes violate amendment 14’s prohibition on local and special acts, as they arbitrarily apply specifically to the employment of certain personnel for the First, Fourth, and Fifth Divisions of the Sixth Judicial Circuit rather than uniformly across the district or the state. The court also rejected the argument of estoppel, stating that the County should not be punished for its previous compliance with the law and should not be estopped from bringing this constitutional challenge. View "Austin v. Hyde" on Justia Law

The case revolves around Jon Comstock, a lawyer who was observing Rule 8.1 hearings in a Benton County jail courtroom. Comstock was seated behind a glass window where he could see but not hear the proceedings due to a malfunctioning or turned-off sound system. He attempted to make Judge Griffin aware of the violation of the constitutional guarantees of open court proceedings. During a break, Judge Griffin and Comstock had a heated exchange about Comstock's right to hear the proceedings, which resulted in Comstock being held in direct criminal contempt and sentenced to five days in Benton County Jail, with four and a half days suspended.Comstock filed an omnibus motion for a new trial, petition for review, and notice of appeal in the Benton County Circuit Court, arguing that the circuit court had jurisdiction to conduct a de novo trial of the contempt finding. The circuit court initially granted Comstock a new trial, but later ruled that it lacked jurisdiction to conduct a trial in the matter and dismissed the case, determining that the contempt order was a final order from a circuit court and that the appellate court was the proper venue for a review of that order.The Supreme Court of Arkansas affirmed the decision of the Benton County Circuit Court. It held that the contempt order was indeed a final order from a circuit court and that the appellate court was the proper venue for a review of that order. The court also found substantial evidence to support the circuit court’s order finding Comstock in direct criminal contempt. Therefore, the court affirmed the circuit court's finding and declined to reach Comstock’s recusal argument. View "Comstock v. State" on Justia Law

The case involves Little Scholars of Arkansas, AP Consolidated Theatres II L.P., CSRC Charter LISA, LLC, and KLS Leasing LLC (collectively, appellants) who appealed against Pulaski County, Arkansas, and its officials (collectively, appellees). The appellants operate charter schools and lease properties for their schools. The appellees assessed real-property taxes against the schools, which the appellants contested, arguing that the properties used for school purposes are exempt from taxes under the Arkansas Constitution. The appellants also sought a declaration that Ark. Code Ann. § 6-21-118, which they claimed the appellees relied on for the tax assessment, is void under the constitution.The case was initially brought before the Pulaski County Circuit Court. The appellees moved to dismiss the case, arguing that the county courts have exclusive jurisdiction over county tax matters. The circuit court agreed with the appellees, dismissing the case on the grounds that it lacked subject-matter jurisdiction over the appellants' claims.The case was then brought before the Supreme Court of Arkansas. The appellants argued that the circuit court did have subject-matter jurisdiction over their illegal-exaction claims. They also argued that their request for a declaration that Ark. Code Ann. § 6-21-118 is void does not fall within the county court’s jurisdiction. The Supreme Court disagreed with the appellants, affirming the circuit court's decision. The Supreme Court held that the appellants' claim was not an illegal-exaction claim but an assessment dispute, which falls within the exclusive original jurisdiction of the county court. The Supreme Court also held that the circuit court did not have subject-matter jurisdiction over the appellants' request for declaratory judgment. View "LITTLE SCHOLARS OF ARKANSAS FOUNDATION v. PULASKI COUNTY, ARKANSAS" on Justia Law