Justia Arkansas Supreme Court Opinion Summaries

A masked individual entered Plato’s Closet in Jonesboro, Arkansas, threatened employees with what appeared to be a handgun, and stole $598 before fleeing in a gray Mercury sedan. Shortly after, law enforcement stopped Pierre Wright, who was driving a vehicle matching the description. Officers found clothing matching the suspect’s, an imitation firearm, and a Plato’s Closet bag containing $598 in the car. Additional evidence, including GPS and cell-phone data, further linked Wright to the crime.The State charged Wright with aggravated robbery and theft of property and sought to classify him as a habitual offender based on prior Tennessee convictions. At trial in the Craighead County Circuit Court, Wright moved for directed verdicts, arguing insufficient evidence of his identity as the robber. The circuit court denied these motions, and the jury found Wright guilty. During sentencing, the State introduced certified records of Wright’s prior Tennessee convictions—one for aggravated robbery and two for aggravated burglary—and argued that the Tennessee aggravated-burglary offenses were comparable to Arkansas’s aggravated residential burglary, making Wright eligible for a mandatory life sentence under Arkansas Code Annotated section 5-4-501(d). The circuit court agreed and imposed the life sentence.On appeal to the Supreme Court of Arkansas, Wright raised three arguments: the sufficiency of the evidence, the comparability of his Tennessee convictions to Arkansas offenses for sentencing enhancement, and the propriety of his mandatory life sentence. The Supreme Court of Arkansas held that the evidence was sufficient to support the convictions, that the circuit court did not abuse its discretion in finding the Tennessee aggravated-burglary convictions comparable to the Arkansas statute, and that the mandatory life sentence was proper. The Court affirmed the judgment and sentence. View "WRIGHT v. STATE OF ARKANSAS" on Justia Law

Six men, including two law enforcement officers and four members of a towing crew, responded to a tractor-trailer accident in St. Francis County, Arkansas, in April 2018. The accident involved an Old Dominion Freight Line truck transporting a 565-pound barrel of formic acid, a hazardous material. Although federal law did not require placarding for this volume, Old Dominion’s driver failed to disclose the presence of hazardous material when asked by emergency responders. The responders were subsequently exposed to toxic fumes, resulting in permanent respiratory and related injuries. All six men sought emergency medical care and later brought negligence claims against Old Dominion and its driver, seeking compensatory and punitive damages.The St. Francis County Circuit Court held a jury trial, which resulted in a verdict for the plaintiffs, awarding them $75 million in compensatory damages and finding no liability for punitive damages. The defendants' post-trial motions for a new trial or remittitur were denied by operation of law. On appeal, the Arkansas Court of Appeals affirmed in part, reversed in part, and ordered a new trial, finding the compensatory damages unsupported by substantial evidence. The parties petitioned for review, which the Supreme Court of Arkansas granted, treating the case as if originally filed there.The Supreme Court of Arkansas affirmed the circuit court’s judgment and vacated the court of appeals’ opinion. It held that, given the immediate and acute toxic exposure, a heightened causation standard was not required, and that the evidence—including expert medical testimony—was sufficient to support the jury’s proximate cause finding. The court further held that the plaintiffs’ claims were not preempted by federal law, the professional-rescuer’s doctrine did not bar recovery, and the evidentiary and procedural rulings below were not abuses of discretion. Finally, the court found the damages award was supported by substantial evidence and was not so excessive as to shock the conscience. View "OLD DOMINION FREIGHT LINE, INC. v. MCMILLION" on Justia Law

Four individuals alleged that they were sexually abused as children by James Nesmith, a pediatric doctor and church counselor, between 1995 and 2007. They claimed the abuse occurred during medical visits, at home, and at a church camp. Their lawsuit sought damages for sexual assault, sexual battery, and infliction of extreme emotional distress under Arkansas tort law and a statute granting crime victims a cause of action. However, the plaintiffs did not file their claims within the standard limitations periods applicable to such actions. Instead, they relied on the Justice for Vulnerable Victims of Sex Abuse Act, which revived and extended the statute of limitations for child sex abuse claims within a specific timeframe. The parties conceded that the plaintiffs’ complaint was filed within the revived window provided by the Act.James Nesmith moved for summary judgment in the Pulaski County Circuit Court, arguing that under the Arkansas Supreme Court’s existing vested-rights precedent, the General Assembly lacked the authority to revive claims that were already time-barred, rendering the Act invalid and the claims untimely. The circuit court agreed and dismissed the complaint on statute of limitations grounds. The Arkansas Court of Appeals affirmed, citing binding precedent that prohibited legislative revival of expired claims.The Supreme Court of Arkansas granted review and reversed the lower courts’ decisions. The court overruled its prior vested-rights precedent, finding no constitutional basis for categorically prohibiting the legislature from reviving time-barred claims through legislation. It upheld the Justice for Vulnerable Victims of Sex Abuse Act, concluding that the General Assembly has the authority to set or extend statutes of limitations, including for previously barred claims. The court reversed the circuit court’s dismissal and remanded the case for further proceedings, and vacated the opinion of the court of appeals. View "H.C. v. NESMITH" on Justia Law

On October 18, 2022, a fatal shooting occurred in the parking lot of The Ridge apartment complex in Little Rock, Arkansas. The evidence at trial established that Ferrad McCoy traveled with Mason Abraham from Memphis to Little Rock, where Abraham, as the passenger in a white Infiniti, shot and killed Broderick Blueford. Law enforcement later pursued the same vehicle on Interstate 40, resulting in a high-speed chase and crash. Both McCoy and Abraham fled on foot but were apprehended nearby. Physical evidence, including firearms, shell casings, a cell phone, and a hoodie matching McCoy’s attire, as well as video footage and cell phone records, linked both men to the crime and location.The Pulaski County Circuit Court presided over a jury trial in which McCoy was convicted of capital murder, first-degree unlawful discharge of a firearm from a vehicle, and firearm enhancements. He received life imprisonment plus additional years for the enhancements. McCoy challenged the sufficiency of the evidence and objected to the admission of several items, including photographs, firearms, video footage, and a “BOLO” flyer. He also raised issues regarding jury instructions and the Confrontation Clause.The Supreme Court of Arkansas reviewed the case, applying the substantial evidence standard and broad discretion for evidentiary rulings. The Court held that there was substantial evidence to support the convictions, properly admitted the contested evidence, and found no reversible error in the circuit court’s rulings. The Court also determined that McCoy’s jury instruction and Confrontation Clause arguments were either waived or without merit. The convictions and sentences imposed by the Pulaski County Circuit Court were affirmed. View "MCCOY v. STATE OF ARKANSAS" on Justia Law

The case centers on a man who shot and killed his wife in their Little Rock home. In the days leading up to the incident, he sent her a series of threatening and incoherent text messages, suggesting jealousy and intent to cause harm. On the day of the shooting, a family friend visited the home and left his .40-caliber Glock handgun on the couch. After an argument between the husband and wife, the friend heard gunshots as he was leaving. He returned to find the wife dead and the husband present but the handgun missing. The husband fled the scene and was later apprehended in Texas, having changed his appearance. During his time in jail, he instructed his daughter to lie to investigators about the nature of his relationship with his wife and whether there had been any conflict.The Pulaski County Circuit Court presided over the trial. During the proceedings, the defendant requested to dismiss his retained counsel midtrial, expressing dissatisfaction with his representation, but had not arranged for another attorney and did not wish to represent himself. The circuit court denied the request, citing the length of time the case had been pending and the absence of substitute counsel. At trial’s conclusion, the jury found him guilty of first-degree murder, a lesser-included offense of the original capital murder charge, and imposed a sentence of life imprisonment plus fifteen years for a firearm enhancement.On appeal, the Supreme Court of Arkansas reviewed whether the circuit court erred in denying the motion to change counsel and whether there was sufficient evidence to support the conviction. The Supreme Court held that substantial evidence supported the verdict and that the circuit court did not abuse its discretion in denying the last-minute motion to change counsel. The conviction and sentence were affirmed. View "BROWN v. STATE OF ARKANSAS" on Justia Law

The case concerns Christopher Franklin, who was serving as the mayor of Helena-West Helena, Arkansas. The State filed a lawsuit against Franklin in June 2025, alleging that he had abused his office and committed various illegal acts. The State sought civil penalties, damages, attorneys’ fees, and Franklin’s removal from office. Unusually, instead of the circuit court clerk issuing and signing the summons as required, the circuit court judge did so after the State handed him the complaint in open court. The next day, the documents were filed with the clerk, and the court issued an ex parte temporary restraining order removing Franklin from his mayoral duties.Franklin responded by filing several motions, including one to dismiss the case on the ground that the summons was defective because it had not been signed by the clerk or a deputy clerk. Despite Franklin’s objections, the Phillips County Circuit Court imposed penalties, awarded attorneys’ fees, and removed him from office. Franklin then filed a motion under Rule 60(a) to vacate the orders, which was deemed denied by operation of law. He appealed the case.The Supreme Court of Arkansas reviewed whether the summons was valid and whether Franklin had waived his objection. The court held that the summons was constitutionally defective because only the clerk or a deputy clerk may sign a summons, not a judge. Since the State did not serve Franklin with a valid summons within the required 120 days, the circuit court lacked personal jurisdiction. The court also determined that Franklin did not waive his objection. As a result, the Supreme Court of Arkansas reversed the circuit court’s orders, vacated all actions taken, and dismissed the case without prejudice. View "FRANKLIN v. STATE OF ARKANSAS" on Justia Law

The dispute involved actions by city officials in Helena-West Helena, Arkansas, concerning two ordinances passed in December 2022 by outgoing city council members. These ordinances, among other things, increased the mayor’s salary from $48,000 to $70,000. The outgoing mayor attempted to veto these ordinances, but the newly elected mayor, Christopher Franklin, sought to rescind the veto. Greg Williams, a local resident, challenged the validity of the ordinances, arguing they had been properly vetoed and were therefore void.The Phillips County Circuit Court initially granted a temporary restraining order against implementation of the ordinances and, after a hearing, issued a declaratory judgment holding the two ordinances null and void. The court did not issue a permanent injunction. The City appealed, and the Supreme Court of Arkansas affirmed the Circuit Court’s declaratory judgment. Subsequently, Williams filed for contempt against Franklin, alleging he had violated the court’s order by accepting the increased salary. The Circuit Court found Franklin in civil contempt for willfully disobeying the declaratory judgment and ordered him to repay part of his salary or face jail.The Supreme Court of Arkansas reviewed the contempt order. The court held that a declaratory judgment, which only settles the rights and obligations of the parties without compelling or prohibiting specific actions, cannot be enforced by contempt; only injunctive orders may be enforced in this manner. Since the Circuit Court’s order was a declaratory judgment, and not an injunction, the contempt finding was improper. The Supreme Court of Arkansas reversed the Circuit Court’s contempt order and dismissed the contempt proceedings. View "FRANKLIN v. WILLIAMS" on Justia Law

The appellant was charged as a habitual offender with kidnapping, rape, and aggravated assault following an incident where he forcibly assaulted and raped a fifteen-year-old girl in Columbia County, Arkansas. The State agreed to a plea deal, which would dismiss the kidnapping charge and recommend concurrent sentences of thirty years for rape, twenty years suspended, and six years for aggravated assault. During the plea hearing, the appellant acknowledged the terms and facts of the case, as well as his prior felony convictions. The circuit court found the plea voluntary and knowing, but ultimately imposed a life sentence for rape and six years for aggravated assault, deviating from the recommended plea agreement terms.After the court accepted the plea but before entry of judgment, the appellant moved to withdraw his guilty plea under Arkansas Rule of Criminal Procedure 26.1, arguing that he had not been given notice that the court would reject the recommended sentence and had not been given an opportunity to withdraw his plea. The Columbia County Circuit Court held a hearing on the motion and found that the plea had been entered voluntarily, with effective assistance of counsel, and with knowledge of the nature of the charges and possible sentences. The court determined that it had not indicated concurrence with the plea agreement and that no manifest injustice warranting withdrawal of the plea had been shown. The sentencing order was entered, and the appellant filed a timely appeal.The Supreme Court of Arkansas reviewed the circuit court’s denial of the motion to withdraw the guilty plea for abuse of discretion. It held that, because the circuit court had not indicated concurrence with the plea agreement, Rule 26.1(b)(v) did not apply, and the appellant did not prove manifest injustice. Arguments regarding lack of notice under Rule 25.3 and involuntariness under Rule 26.1(b)(iii) were not preserved for appellate review. The court affirmed the circuit court’s decision. View "DAVIS V. STATE OF ARKANSAS" on Justia Law

Wesley Cooper fatally shot his neighbor, Donald Lewis, and his uncle, Terry Brasuell in Crawford County in 2023. Cooper, under the influence of drugs, mistakenly believed that Lewis and Brasuell had killed his family after he was unable to contact them, not realizing they were merely camping in a location without cell service. He purchased black clothing for his intended actions, stole two handguns from his father's safe, and proceeded to carry out both killings. After the second shooting, a neighbor, Melinda Ball, witnessed the event and relayed her account to police officers, which was subsequently documented by another neighbor, Helene Plonski, at the direction of law enforcement. Cooper was arrested and confessed to both murders.The Crawford County Circuit Court presided over Cooper's trial. Prior to trial, Melinda Ball passed away. Cooper moved to exclude Ball’s written statement on hearsay and confrontation grounds, arguing he had no opportunity to cross-examine her. The circuit court denied his motion, finding the statement admissible as a present sense impression and excited utterance, but did not rule specifically on the confrontation issue. The statement was introduced at trial, and Cooper renewed his objections, which were denied without explicit consideration of the confrontation argument. The jury convicted Cooper on both counts of capital murder, imposing two life sentences without parole.The Supreme Court of Arkansas reviewed the case, focusing solely on Cooper’s appeal regarding the conviction for Brasuell’s murder. The court held that the admission of Ball’s statement did violate Cooper’s right to confront witnesses against him, as the statement was testimonial and Cooper had no prior opportunity for cross-examination. However, the court found the error harmless beyond a reasonable doubt, given Cooper’s confession and corroborating eyewitness evidence. The conviction and sentence were affirmed. View "WESLEY v. STATE OF ARKANSAS" on Justia Law

Kristina Gulley, who previously served as justice of the peace for District 10 in Pulaski County, Arkansas, sought reelection after having been disqualified in earlier proceedings due to two prior misdemeanor hot-check convictions from 1997 and 2003. Multiple prior legal actions had resulted in findings that these convictions constituted “infamous crimes” under article 5, section 9 of the Arkansas Constitution, rendering her ineligible to run for or hold public office. Despite these rulings, Gulley again filed as a candidate in the 2026 primary election. Registered voters in the district challenged her eligibility, seeking a declaratory judgment and writ of mandamus to prevent her name from appearing on the ballot and to prohibit counting any votes cast for her.The Pulaski County Circuit Court held an expedited hearing, denied Gulley’s requests for a continuance and for relief from judgment, and reaffirmed her ineligibility based on the prior convictions. The court found that neither the sealing of her record nor a gubernatorial pardon restored her eligibility to run for office, and it ordered the Board of Election Commissioners not to certify her as a candidate or count votes for her. Gulley appealed, challenging the circuit court’s findings on factual and constitutional grounds. However, she did not obtain a stay of the court’s order or the certification of the election results.Upon review, the Supreme Court of Arkansas determined that the appeal was moot because the March 2026 primary election had already occurred, and the election results had been certified. The court held that no effective relief could be granted as to the election in question, and none of the recognized exceptions to the mootness doctrine applied. Accordingly, the Supreme Court of Arkansas granted the motion to dismiss the appeal as moot and dismissed the case. View "GULLEY v. JEFFREY" on Justia Law