Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree felony murder, two counts of aggravated robbery, and a firearm enhancement and sentencing Appellant as a habitual offender to life imprisonment, holding that the circuit court did not err in denying Appellant's motions for directed verdict or his motion to suppress and did not sentence him illegally. Specifically, the Court held (1) contrary to Appellant's argument on appeal, substantial evidence supported the first-degree murder conviction and one of the aggravated robbery convictions; (2) the circuit court did not err by sentencing Appellant as a habitual offender to a term of life imprisonment because he had two prior convictions for crimes that he had committed as a minor and for which he was tried as an adult; and (3) the circuit court did not err in denying Defendant's motion to suppress his taped statement to police during which he requested an attorney. View "Price v. State" on Justia Law

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The Supreme Court affirmed Appellant's convictions for capital murder and aggravated robbery, holding that none of Appellant's allegations of error warranted reversal. Specifically, the Court held (1) the State presented sufficient circumstantial evidence to support the convictions, and therefore, the circuit court did not err in denying Appellant's motion for directed verdict; (2) the circuit court did not abuse its discretion by denying Appellant's motion to exclude as hearsay testimony about the businesses Appellant called after the shooting; and (3) the circuit court did not err in denying Appellant's posttrial motion for mistrial because the jury's verdicts were consistent. View "Finley v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the circuit court dismissing for lack of jurisdiction Appellant's appeal from a district court judgment convicting him of driving while intoxicated and a speeding violation, holding that the circuit court erred in granting the State's motion to dismiss based not he circuit court's lack of jurisdiction. The circuit court dismissed Appellant's appeal of his conviction in district court as untimely pursuant to Ark. R. Crim. P. 36(c). On appeal, Appellant argued that the circuit court erred because the appeal was timely filed pursuant to Rule 36(d). The Supreme Court reversed, holding that the filing of Appellant's affidavit triggered jurisdiction of his appeal and strictly complied with Rule 36(d) to commence an appeal from the district court to the circuit court. View "Treat v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed Appellant's appeal from an order of the circuit court dismissing without prejudice his pro se "motion for writ of mandamus order," holding that Appellant appealed from an order that was not final, rendering his motions and petition filed in relation to the appeal moot. The circuit court dismissed Appellant's motion for failure to provide proof of service in compliance with Ark. R. Civ. P. 4(i)(1). Appellant appealed and filed a motion to proceed without a complete record, a "third motion to file incomplete record, motion for extension of time, and motion against the clerk," a petition for certiorari to complete the record, and a motion seeking waiver of the addendum obligation. The Supreme Court dismissed the appeal, holding that the order from which Appellant appealed was not final. View "Hill v. Honorable Jodi Dennis" on Justia Law

Posted in: Civil Procedure
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The Supreme Court affirmed the order of the circuit court certifying a class pursuant to Ark. R. Civ. P. 23, holding that the circuit court properly granted the class certification filed by Appellees. Appellees, employees of Appellant, filed their class-action complaint alleging breach of contract and unjust enrichment based on Appellant's failure to compensate them for earned but unused vacation time. The circuit court entered an amended order granting class certification. The Supreme Court affirmed, holding (1) Appellees met their burden of proof as to the commonality requirement; (2) Appellees met their burden of proof as to the predominance requirement; and (3) a class action was a superior means of resolving the contractual dispute at the heart of this case. View "Industrial Welding Supplies of Hattiesburg, LLC v. Pinson" on Justia Law

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In this case alleging unjust enrichment, breach of contract, and promissory estoppel the Supreme Court reversed the order of the circuit court denying Appellants' motion for class certification, holding that the circuit court abused its discretion in concluding that Appellants did not meet the Ark. R. Civ. P. 23 requirements for class certification. Appellants, former employees of Cooper Clinic, P.A., filed a class-action complaint against Cooper Clinic and the entities that acquired Cooper Clinic's assets (collectively, Mercy). Appellants sought to certify a class to consist of individuals who worked for Cooper Clinic and were terminated as part of the merger with Mercy without being paid for their unused vacation time. The circuit court denied the motion for class certification on the basis that all former employees had eventually been paid for their unused vacation time. The Supreme Court reversed, holding that the class of individuals who were not paid for their unused vacation time at the time of the termination of their employment with Cooper Clinic still existed and that the circuit court abused its discretion by relying on Cooper Clinic's payments to employees with unused vacation-time balances to defeat Rule 23's requirements. View "Vaughn v. Mercy Clinic Fort Smith Communities" on Justia Law

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The Supreme Court affirmed Defendant's convictions of rape and second-degree sexual assault, holding that the circuit court did not commit prejudicial error in allowing testimony from Defendant's daughter under the pedophile exception and allowing the State to inquire on cross-examination about a disputed police report. Specifically, the Court held (1) the circuit court did not abuse its discretion when it admitted the testimony of Defendant's daughter that Defendant sexually abused her when she was five or six years old; and (2) the circuit court erred by allowing the State to inquire on cross-examination about a disputed police report, but the error was harmless. View "Lowery v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed Defendant's four convictions of negligent homicide, holding that the circuit court did not err by denying Defendant's motions for directed verdict. During trial, Defendant moved, unsuccessfully, for a directed verdict both at the close of the State's evidence and at the close of all the evidence. The Supreme Court reversed Defendants convictions and dismissed the case, holding that the circuit court erred in denying Defendant's motions for directed verdict. Specifically, the Court held that the State failed sufficiently to prove that Defendant should have been aware of a substantial risk that deaths would occur as a result of his conduct and that his conduct grossly deviated from the standard of care that a reasonable person would have exercised under the circumstances. View "Ledwell v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner failed to show that he was entitled to the writ. In his petition, Petitioner argued that the State and his trial attorneys violated Brady v. Maryland, 373 U.S. 83 (1963), by failing to disclose certain statements by police officers and that there was an error during his trial. The Supreme Court denied the petition, holding that because the petition reasserted an allegation previously raised in this Court and an issue of trial error that is outside the scope of a coram-nobis proceeding, Petitioner was not entitled to coram-nobis relief. View "Hutcherson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the circuit court's dismissal of Appellant's pro se complaint alleging constitutional violations of his right to due process and constitutional violations of the ex post facto prohibition in connection with the denial of his application for parole, holding that Appellant's sole claim on appeal was abandoned. On appeal, Appellant argued for the first time that Appellees violated his right to equal protection because he had been treated differently from similarly situated inmates. The Supreme Court affirmed the circuit court's order dismissing Appellant's complaint, holding that because Appellant did not raise the argument below the issue could not be considered by this Court. View "Boydston v. Kelley" on Justia Law

Posted in: Criminal Law