Justia Arkansas Supreme Court Opinion Summaries

John Mercer was charged with two counts of driving while intoxicated (DWI) in Garland County, Arkansas, in 2017. He pled no contest to both charges in 2018. The Garland County District Court imposed fines, required alcohol education, and placed Mercer on at least six months of probation, which included a $25 monthly probation fee and conditions such as random drug and alcohol testing. Mercer made several probation-fee payments as a result. Mercer later filed a lawsuit, alleging that probation and associated fees in DWI cases are not authorized under Arkansas law and therefore constitute an illegal exaction. He also asserted federal and state due-process claims, seeking declaratory and injunctive relief and repayment of the fees collected.The Garland County District Court moved to dismiss Mercer’s complaint in the Garland County Circuit Court, arguing that it was entitled to sovereign immunity under the Arkansas Constitution. The circuit court denied the motion to dismiss, rejecting the sovereign immunity defense. After further proceedings and amended complaints, the district court again sought dismissal, but the circuit court denied the motion. The district court then filed an interlocutory appeal to the Supreme Court of Arkansas, challenging the denial of sovereign immunity.The Supreme Court of Arkansas held that Mercer’s illegal-exaction claim may proceed because the Arkansas Constitution expressly authorizes such claims, overriding sovereign immunity. The court also held that Mercer’s federal due-process claim survives dismissal, as state sovereign immunity cannot categorically bar federal causes of action in state courts of general jurisdiction. However, the court ruled that Mercer’s Arkansas Civil Rights Act claim is barred by sovereign immunity, as there is no constitutional authorization for such suits against the state. The court affirmed the circuit court’s order in part, reversed it in part, and remanded the case for further proceedings. View "GARLAND COUNTY DISTRICT COURT v. MERCER" on Justia Law

Duane Gonder, an inmate serving a lengthy prison sentence following guilty pleas to multiple charges in 2010, filed a petition for declaratory and injunctive relief against the Arkansas Attorney General. He challenged the constitutionality of Arkansas Code Annotated section 5-54-119(a), which criminalizes furnishing prohibited articles in correctional facilities. Gonder contended that the statute, as interpreted in Laster v. State, 76 Ark. App. 324, 64 S.W.3d 800 (2002), was unconstitutional as applied to him and other inmates who never leave the prison facility, arguing that it violated due process and equal protection. He asserted that he and similarly situated inmates faced a threat of prosecution for actions that, under his reading of the statute, should not apply to them.The Pulaski County Circuit Court, Third Division, dismissed Gonder’s petition without prejudice. The circuit court found that Gonder lacked standing and failed to present a justiciable controversy, and imposed a strike under applicable Arkansas law. The court reasoned that Gonder’s claims were speculative and hypothetical, rather than based on a present injury or sufficient facts to establish an actual controversy. Gonder appealed this decision.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s dismissal. The court held that Gonder had not alleged sufficient facts demonstrating standing, as he did not show a present injury or a concrete threat of prosecution under the challenged statute. The court further agreed that no justiciable controversy existed, as Gonder’s claims were speculative and not ripe for judicial determination. As a result, the dismissal without prejudice became a dismissal with prejudice, and Gonder’s motion for a decision based on his brief alone was rendered moot. The imposition of a strike was also affirmed. View "GONDER v. GRIFFIN" on Justia Law

The appellant was charged with multiple felonies arising from a violent altercation involving his wife. The prosecution alleged that, during an argument on February 17, 2024, the appellant physically assaulted his wife, restrained her with zip ties and duct tape, threatened her with a gun, burned her with a heated knife, and prevented her from leaving her residence. The victim eventually managed to escape and, assisted by a friend, sought medical attention for her injuries. Physical evidence, including photographs of burns and marks matching her account, as well as the appellant’s fingerprints on a roll of duct tape, were introduced at trial.The case was tried before the Faulkner County Circuit Court, after the appellant waived his right to a jury trial. At trial, both the victim and her friend testified regarding the events and subsequent escape. The appellant denied the allegations and challenged the credibility and plausibility of the testimony and evidence. The circuit court, after evaluating the witnesses' credibility, found the appellant guilty of kidnapping, aggravated residential burglary, first-degree domestic battering with a deadly weapon, aggravated assault on a family or household member, first-degree terroristic threatening, and fleeing. The court imposed two life sentences to run consecutively, plus an additional thirty-one years’ imprisonment.The Supreme Court of Arkansas reviewed two arguments on appeal: first, that the circuit court erred in denying motions to dismiss based on the alleged implausibility and insufficiency of the evidence; second, that the court improperly allowed defense counsel to represent the appellant despite lacking specific certification for Class Y felonies. The Supreme Court held that the appellant’s sufficiency challenge was not preserved for appeal due to the lack of specificity in his motions below. The court also held that the argument regarding defense counsel’s certification was not preserved and did not constitute a structural error. The convictions and sentences were affirmed. View "THORNTON V. STATE OF ARKANSAS" on Justia Law

US Beef Corporation, headquartered and commercially domiciled in Oklahoma, operated restaurant franchises in several states, including Arkansas. In 2018, US Beef sold all its assets—its Taco Bueno and Arby’s franchises, including both tangible and intangible property—after receiving unsolicited offers. This was a complete liquidation and ended the business’s operations. Prior to this sale, US Beef had never engaged in such a transaction. On its 2018 Arkansas corporate income tax return, US Beef treated the gains from the sales of intangible assets as “nonbusiness income,” allocating them to Oklahoma, its commercial domicile, and sought a refund for Arkansas estimated tax payments.The Arkansas Department of Finance and Administration (DFA) denied the refund, classifying the gain as “business income” apportionable to Arkansas. US Beef appealed administratively, but the Office of Hearings & Appeals upheld DFA’s position. US Beef then sought judicial review in Pulaski County Circuit Court, seeking a declaration that the gain was nonbusiness income under the pre-2026 version of Arkansas’s Uniform Division of Income for Tax Purposes Act (UDITPA). The parties agreed only the “functional test” for business income was at issue. The circuit court granted summary judgment to US Beef, holding the gain was nonbusiness income under the statute and thus not taxable in Arkansas.The Supreme Court of Arkansas reviewed the case de novo and affirmed the circuit court’s decision. The court held that under the applicable statute and precedent, the gain from the sale of US Beef’s intangible assets did not satisfy the functional test for business income because US Beef was not in the regular business of disposing of such assets—its regular business was operating franchises, not selling them. Therefore, the gain was nonbusiness income allocable to Oklahoma, and the judgment in favor of US Beef was affirmed. View "HUDSON v. UNITED STATES BEEF CORPORATION" on Justia Law

A man was charged with capital murder, rape, kidnapping, and residential burglary after confessing to abducting, sexually assaulting, and killing a six-year-old girl who was his neighbor. The prosecution presented evidence including his detailed confession, DNA linking him to the crime, and medical testimony supporting the cause of death and sexual assault. During the penalty phase, the defense introduced extensive mitigating evidence about his traumatic and abusive childhood, including substance abuse by his mother, physical and sexual abuse, learning disabilities, and his low intellectual functioning.Following a jury trial in the Benton County Circuit Court, the defendant was convicted on all charges and received the death penalty for capital murder, along with life sentences and additional imprisonment for the other offenses. The defense’s mitigation efforts included testimony by social workers, family members, and mental health experts, but the jury found that aggravating circumstances outweighed the mitigating evidence. The Arkansas Supreme Court had previously affirmed his convictions and sentences on direct appeal.The Supreme Court of Arkansas reviewed the denial of his postconviction petition, which alleged ineffective assistance of counsel on several grounds, including failure to adequately investigate and present evidence of childhood sexual abuse and fetal alcohol spectrum disorder (FASD), omission of a mitigating instruction regarding his lack of criminal history, and wrongful concession of guilt without his consent. The court held that trial counsel was not deficient in its investigation or presentation of mitigating evidence, found no prejudice from the omission of certain mitigators, determined that the concession of guilt was a reasonable strategic decision under the circumstances, and rejected arguments regarding verdict forms and cumulative error. The Supreme Court of Arkansas affirmed the lower court’s denial of postconviction relief. View "HOLLY v. STATE OF ARKANSAS" on Justia Law

A juvenile, referred to as MC, was charged with capital murder and aggravated robbery following the fatal shooting of a fifteen-year-old in Little Rock, Arkansas. After being charged in Pulaski County Circuit Court, MC filed a motion to have his case transferred to the court’s juvenile division, citing the juvenile transfer statute. MC presented evidence including his lack of criminal history, good school performance, and positive behavior in custody, along with testimony from supportive witnesses. The State offered evidence about the violent circumstances of the crime, including details from the lead detective about the shooting and the discovery of a firearm at MC’s grandmother’s home.The Pulaski County Circuit Court granted MC’s motion, finding that he had met the burden of proof for transfer and making written findings on the statutory factors. Most notably, the court found there was no evidence regarding whether the offense was committed in an aggressive, violent, premeditated, or willful manner. The State appealed, arguing that the juvenile transfer statute allows either party to appeal a transfer order. Both parties acknowledged that prior Arkansas Supreme Court precedent in State v. A.G. had foreclosed such appeals by the State.The Supreme Court of Arkansas reviewed the case. It overruled State v. A.G., holding that the Arkansas Constitution allows the legislature to authorize appeals from non-final orders, including juvenile transfer decisions. The court found that the circuit court clearly erred in concluding there was no evidence of violence in the manner of the offense, given the direct testimony about the shooting. The Supreme Court reversed the transfer order and remanded the case for further proceedings. View "STATE OF ARKANSAS v. MINOR CHILD" on Justia Law

Raunona Mays, an African American woman employed as a Sergeant with the Arkansas Highway Police, applied for four promotions between 2022 and 2023 but was denied each time. She alleges that less qualified Caucasian males or individuals with less experience and education received the positions. After filing an internal grievance regarding one promotion and receiving no relief, Mays filed an Equal Employment Opportunity Commission (EEOC) complaint alleging race and sex discrimination, as well as retaliation. The EEOC dismissed her charge and issued a right-to-sue letter, after which Mays brought suit seeking damages, a promotion, and injunctive relief.The Pulaski County Circuit Court denied the Arkansas Highway Police’s motion to dismiss, which was based on sovereign immunity. The agency argued that it could not be sued under the United States Constitution and federal statutes, as well as the Arkansas Civil Rights Act, because it is protected by sovereign immunity. The circuit court rejected this argument, allowing all claims to proceed.The Supreme Court of Arkansas reviewed the appeal and held that Mays’s claims under 42 U.S.C. § 1983, 42 U.S.C. § 1981, and the Arkansas Civil Rights Act could not proceed against the state agency because the agency is not considered a “person” under these statutes and is protected by sovereign immunity. The court reversed and remanded those claims for dismissal. However, the court determined that claims under Title VII of the Civil Rights Act of 1964 are not barred by sovereign immunity when brought against a state agency, and that Mays had pleaded sufficient facts to state a Title VII claim. The decision of the Pulaski County Circuit Court was affirmed as to the Title VII claim but reversed and remanded for dismissal of the other claims. View "ARKANSAS HIGHWAY POLICE v. MAYS" on Justia Law

After a long-term romantic relationship began to deteriorate between Elijah Singleton and Ja’Keya Hampton, Singleton stole Hampton’s cellphone and refused to return it. The day before Hampton’s death, the two communicated via Facebook Messenger, arranging to meet so Singleton could return the phone. Hours later, Hampton was found dead in her car from a gunshot wound. Surveillance footage captured the shooting, with audio indicating Hampton called out to Singleton moments before being shot. After the incident, Singleton attempted to elude law enforcement and destroy evidence, but was arrested following a standoff. He was charged with capital murder and a firearm enhancement.During jury selection in the Crittenden County Circuit Court, a prospective juror who worked at the county jail expressed concerns about a conflict of interest in open court, prompting Singleton to move for a mistrial, which was denied. The State exercised peremptory strikes against four Black prospective jurors. Singleton raised a Batson challenge, arguing the strikes were racially motivated. The State provided race-neutral reasons, such as relationships with the victim’s family, perceived reluctance to serve, and inattentiveness. The circuit court credited the State’s reasons, found them race-neutral, and denied the Batson challenge. Singleton was convicted of first-degree murder and employing a firearm, and sentenced as a habitual offender.On appeal, the Supreme Court of Arkansas reviewed Singleton’s claims that the circuit court erred in denying his mistrial motion and his Batson challenge. The court held there was no abuse of discretion in denying the mistrial because the prospective juror’s statement did not prejudice the jury. It further held that the circuit court’s findings regarding the Batson challenge were not clearly against the preponderance of the evidence. The Supreme Court of Arkansas affirmed the convictions. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

A bank made a $1.9 million loan secured by a mortgage on over 750 acres of real property. About a year later, a portion of the property was sold to a third party, who financed the purchase with a loan from a second bank. During the closing, a vice president of the first bank assured the title company that the bank would release its mortgage on the sold parcel. Relying on this representation, the title company distributed the proceeds, and the second bank lent money for the purchase. Years later, the first bank attempted to enforce its mortgage against the property, claiming its lien was superior to the interests of the second bank and the purchaser.The Lincoln County Circuit Court heard the case after the original borrowers filed for bankruptcy, which stayed claims against them except for breach of contract and foreclosure. The first bank obtained a default judgment for breach of contract against the borrower, but the case continued against the subsequent purchaser and the second bank. These parties moved for summary judgment, arguing the first bank was estopped from asserting its lien due to its agent’s prior representation. The circuit court granted summary judgment in their favor, and the first bank appealed. The Arkansas Court of Appeals dismissed the appeal for lack of a final order due to ambiguous abandonment of unresolved claims.The Supreme Court of Arkansas reviewed the case and held that the first bank’s abandonment of pending claims in its notice of appeal was sufficient for finality, allowing the appeal to proceed. On the merits, the court found no disputed material facts regarding the agent’s authority or the parties’ reliance on the representation. The Supreme Court affirmed the circuit court’s grant of summary judgment, holding that equitable estoppel barred the first bank from enforcing its lien under these circumstances. The opinion of the Court of Appeals was vacated. View "RELYANCE BANK, N.A. v. PHARR" on Justia Law

A company sought to operate a red-dirt surface mine on approximately twenty acres in a part of Washington County that was zoned for agricultural and single-family residential uses. The company, operating as Heritage Farms, applied for a conditional use permit, which the Washington County Planning Board considered and ultimately denied. The company then appealed this denial to the Washington County Quorum Court, which upheld the Planning Board’s decision and adopted an ordinance reflecting the denial. The company further appealed to the Washington County Circuit Court. During the circuit court proceedings, several local residents and a neighborhood association were allowed to intervene. The company moved for summary judgment, arguing that the denial was arbitrary and capricious, while the intervenors and county argued that the proper standard of review was arbitrary and capricious because the action was legislative, and that there was a rational basis for the denial.The Washington County Circuit Court found that the quorum court’s denial of the permit was a legislative act and thus applied the arbitrary-and-capricious standard of review. The court also held that Arkansas Code Annotated section 14-17-211 was unconstitutional to the extent that it permitted de novo review of legislative zoning decisions. Applying the arbitrary-and-capricious standard, the circuit court concluded there was a rational basis for the denial and affirmed the quorum court’s action. The Arkansas Court of Appeals then affirmed the circuit court’s order.The Supreme Court of Arkansas reviewed the case and held that the denial of the conditional use permit was a quasi-judicial act, not a legislative one, because it involved applying existing ordinance provisions to the facts of the application rather than creating new law. Therefore, the circuit court should have conducted a de novo review rather than applying the arbitrary-and-capricious standard. The Supreme Court of Arkansas reversed the circuit court’s judgment, vacated the Court of Appeals’ opinion, and remanded the case for further proceedings. View "MMSC, LLC V. WASHINGTON COUNTY, ARKANSAS" on Justia Law