Justia Arkansas Supreme Court Opinion Summaries

by
The Supreme Court reversed the order of the circuit court disqualifying Stephen Goldman from further participation as the counsel of The Travelers Indemnity Company in a suit filed by the Board of Trustees of the University of Arkansas, holding that the circuit court abused its discretion.The Board, acting on behalf of the University of Arkansas for Arkansas System, brought this complaint against Travelers for breach of contract, declaratory judgment, and bad faith, alleging that it was entitled to benefits under its all-risk commercial insurance policy for damages it suffered during the coronavirus pandemic. After the circuit court entered its ruling disqualifying Goldman, a nonresident attorney, from further representing Travelers in this case Goldman and Travelers (together, Appellants) appealed, arguing that the circuit court erred by revoking Goldman's motion for admission pro hac vice. The Supreme Court agreed and reversed in part, holding that the circuit court's revocation of Goldman's pro hac vice status without prior notice or a reasonable opportunity to be heard violated due process requirements. View "Travelers Indemnity Co. v. Board of trustees of University of Ark." on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court certifying this class action against an auto insurance company brought by Plaintiffs, insureds who incurred medical expenses because of car accidents, holding that the circuit court did not abuse its discretion in concluding that the prerequisites of a class action had been satisfied.Instead of paying Plaintiffs for the full amount of billed medical expenses Defendant instead simply reimbursed them for the actual amount they owed their medical providers after all discounts had been applied. Plaintiffs brought this action that this practice constituted breach of contract and unjust enrichment. The court certified a class action, from which Defendant appealed. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it certified this case as a class action. View "Shelter Mutual Insurance Co. v. Baggett" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of mandamus against the City of Little Rock, holding that there was no error or abuse of discretion.Appellant brought a complaint for declaratory judgment, injunctive relief, and a writ of mandamus, arguing that Act 1024 of 2021 gave holders of an enhanced concealed carry license the right to carry a concealed weapon in municipal buildings. Appellant then brought this action seeking a writ of mandamus seeking to enforce the laws allowing enhanced concealed carry licensees to enter municipal buildings. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant could not demonstrate that the circuit court abused its discretion in denying his mandamus petition. View "Corbitt v. City of Little Rock" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court denying Defendant's Rule 37 petition alleging ineffective assistance of counsel during his criminal trial, holding that there was no error or abuse of discretion.Defendant was convicted of and sentenced to death for capital murder. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief arguing that his trial counsel were constitutionally ineffective for multiple reasons. The circuit court denied the petition. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Holland v. State" on Justia Law

by
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of error coram nobis and his petition for writ of habeas corpus, holding that there was no error or abuse of discretion.Appellant was convicted of rape and first-degree battery and sentenced to life imprisonment. In his petition for writ of error coram nobis Appellant argued that the outcome of the proceedings would have been different had certain testimony been allowed. The circuit court denied the petition. For reversal, Appellant argued that the Supreme Court should adopt the "tentative expansion" of the writ of error coram nobis set forth in Strawhacker v. State, 500 S.W.3d 716 (Ark. 2016). The Supreme Court affirmed, holding (1) because Appellant requested an expansion of the writ that already existed, his argument was moot; and (2) the circuit court did not abuse its discretion in denying coram nobis relief. View "Strawhacker v. State" on Justia Law

Posted in: Criminal Law
by
In this case concerning the medical marijuana licensing and regulatory process the Supreme Court affirmed in part and dismissed in part this interlocutory appeal from the circuit court's denial of Defendants' motion to dismiss this action on the basis of sovereign immunity, holding that the circuit court erred in its ruling.Plaintiff brought this complaint seeking a writ of mandamus and declaratory relief to compel Defendants - the Arkansas Department of Finance and Administration, the Arkansas Alcoholic Beverage Control Division, and the Arkansas Medical Marijuana Commission - to revoke a cultivation facility license granted to another company and instead award it to Plaintiff. The circuit court denied Defendants' motion to dismiss on the doctrine of sovereign immunity. The Supreme Court remanded the action, holding (1) the circuit court did not err in denying the motion to dismiss the writ of mandamus on the basis of sovereign immunity; (2) the circuit court erred in denying gate State's motion to dismiss Plaintiff's claim of declaratory relief; and (3) to the extent that Appellants were seeking relief under the APA the case must be dismissed for lack of subject matter jurisdiction. View "Arkansas Department of Finance & Administration v. 2600 Holdings, LLC" on Justia Law

by
Legal Aid submitted an Arkansas Freedom of Information Act (FOIA) request to the Division of Workforce Services (DWS) seeking information about how DWS and its third-party vendors determined eligibility for applicants of the Unemployment Insurance and/or Pandemic Unemployment Assistance programs. Item 10 sought “[a]ll public records, including communications, created by, sent by, sent to, or otherwise provided to DWS employees between March 1, 2020, and present that contain the words ‘algo’ or ‘algorithm’ in singular or plural form.” Legal Aid did not request confidential information about any claimant.After DWS failed to provide a timeline for the production of the documents, Legal Aid filed suit. DWS’s representative testified that the records responsive to Item 10 were expected to comprise more than 42,000 pages of emails that had to be printed, reviewed, and redacted. The circuit court ordered DWS to submit an estimated timeline for production and to provide records on a weekly basis in accordance with its timeline. Legal Aid subsequently claimed that DWS redacted information that concerned algorithms, or factors, that the agency uses in its processes to determine benefit eligibility. DWS cited ongoing fraud investigations. The Arkansas Supreme Court affirmed an order that the unredacted documents be produced, and that access to and management of the documents be limited. The court found that neither the law enforcement nor the competitive advantage FOIA exception applied. View "Arkansas Department of Commerce, Division of Workforce Services v. Legal AId of Arkansas" on Justia Law

by
The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition.Appellant was found guilty of, among other things, four counts of aggravated robbery and other convictions. Appellant was sentenced to an aggregate term of 240 years' imprisonment. In his writ of habeas corpus, Appellant argued, among other things, that incorrect dates rendered the judgment and commitment order illegal on its face. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant did not allege a cognizable claim and failed to demonstrate probable cause for issuance of the writ. View "Hutcherson v. Payne" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111 in which Appellant alleged that his sentence was illegal, holding that the trial court did not err in finding that Appellant's claims were untimely and that he otherwise failed to demonstrate that his sentences were facially illegal.Appellant pleaded guilty to two counts of first-degree murder and was sentenced to an aggregate term of forty-five years' imprisonment. Appellant later brought this petition, arguing that his sentences departed from the presumptive sentence for first-degree murder as prescribed by Arkansas's sentencing statutes. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant's sentences were facially legal and that the trial court did not clearly err when it denied Manuel's petition. View "Manuel v. State" on Justia Law

Posted in: Criminal Law
by
The Supreme Court affirmed the order of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. Code Ann. 16-90-111, in which he argued that the judgment in his criminal case was facially illegal because his sentence of life imprisonment exceeded the maximum sentence authorized for a Class Y felony, holding that the sentence imposed was not an illegal sentence.In an earlier petition for writ of habeas corpus Appellant raised the same claim that he brought in his petition for postconviction relief. The Supreme Court had concluded that Appellant's life sentence was clearly within the sentencing range for the offense of first-degree murder. As to Appellant's postconviction motion, the Supreme Court denied relief, holding that Appellant was sentenced within the permitted statutory range for first-degree murder, and Appellant failed to establish that the sentence was illegal on its face. View "McArty v. State" on Justia Law

Posted in: Criminal Law