Justia Arkansas Supreme Court Opinion Summaries

The appellant was convicted by a Faulkner County jury of capital murder and sentenced to life imprisonment. The victim, William Holt, was discovered dead in a creek, with evidence including testimony from the appellant’s girlfriend, Jessica Eiss, who stated that the appellant struck Holt with a shotgun during an argument. Eiss testified she remained in the car while the appellant and Holt walked along the creek, and the appellant later returned alone and covered in blood. Investigators found that Holt’s financial affairs connected him to the appellant and Eiss, and evidence included the appellant’s DNA at the crime scene.Following his conviction, which was affirmed on direct appeal by the Supreme Court of Arkansas, the appellant filed petitions under Arkansas Rule of Criminal Procedure 37.1 in the Faulkner County Circuit Court, alleging ineffective assistance of trial and appellate counsel on several grounds. He also sought a copy of the trial transcript and requested an evidentiary hearing. The circuit court denied the petition, finding that the appellant failed to show counsel’s performance was deficient or prejudicial under the Strickland v. Washington standard. It made written findings on each claim and did not conduct an evidentiary hearing, concluding the record showed no entitlement to relief.The Supreme Court of Arkansas reviewed the circuit court’s decision for clear error and affirmed. The court held that the appellant did not provide sufficient factual substantiation for his ineffective assistance claims, that counsel’s actions were consistent with reasonable professional judgment, and no reasonable probability existed that the outcome would have been different. The court further held that failure to rule on the transcript request waived the issue for appeal and that an evidentiary hearing was unnecessary because the record conclusively showed no entitlement to relief. The decision of the Faulkner County Circuit Court was affirmed. View "NOWELL v. STATE OF ARKANSAS" on Justia Law

On February 13, 2024, law enforcement found the body of Teangela Tate, who had died from gunshot wounds, near an interstate ramp in North Little Rock, Arkansas. Nearby, two young children were discovered: one deceased (MV1) from blunt-force trauma and environmental exposure, and another (MV2) alive but barely responsive. Evidence at the scene and subsequent investigation linked Willie Leon Mott, Jr. to the victims, including blood and shell casings in Mott’s house and his mother’s car, cell phone records showing travel to and from the crime scene, and DNA tests. Mott was arrested later that day, and during his incarceration, he attempted to have his mother destroy his cell phone.The Pulaski County Circuit Court presided over Mott’s trial. After the prosecution rested, Mott moved for directed verdicts, arguing insufficient evidence for each count and challenging the constitutional validity of a portion of Arkansas’s capital-murder statute. The circuit court denied these motions, finding the evidence sufficient and the statute not vague. Mott rested without presenting witnesses and renewed his motions, which were again denied. He received life sentences for first-degree murder, capital murder, and attempted capital murder.The Supreme Court of Arkansas reviewed the appeal. Applying the substantial evidence standard, the court determined that the jury’s verdicts were supported by the evidence, including circumstantial evidence and Mott’s actions to conceal his involvement. The court also reaffirmed prior decisions that the statutory language “under circumstances manifesting extreme indifference to the value of human life” is not unconstitutionally vague. The court affirmed the circuit court’s rulings and Mott’s convictions and sentences. View "MOTT v. STATE OF ARKANSAS" on Justia Law

In this case, the defendant was convicted of two counts of capital murder and three counts of terroristic threatening, with firearm enhancements, following the deadly shooting of a woman, Sade Turner, and her unborn child. The prosecution’s evidence included testimony that the defendant, along with his brother, drove to a location in Little Rock and fired multiple shots into a car driven by Turner. After the incident, the brothers returned home, and a burned vehicle matching their Jeep was later found. A key piece of evidence involved a phone conversation overheard by Mykell McFee, who later recounted this conversation to law enforcement during an investigation into a separate murder.During the trial in the Pulaski County Circuit Court, McFee was called as a witness but claimed not to recall the details of his statements made during his interview with police. The prosecution played a recording of McFee’s interview over the defendant’s objection, which was based on the argument that McFee’s lack of memory rendered him unavailable for effective cross-examination, thus violating the defendant’s Sixth Amendment confrontation rights. The Pulaski County Circuit Court overruled the objection, determining that because McFee was present and subject to questioning, there was no confrontation violation.On appeal, the defendant argued to the Supreme Court of Arkansas that the introduction of statements made by another individual, now deceased, within the recorded interview further violated his confrontation rights. The Supreme Court of Arkansas held that this particular argument was not preserved for appellate review because it had not been specifically raised at trial. The court affirmed the conviction, concluding that only the objection presented to the trial court was preserved and that the new confrontation argument could not be considered. View "HOLLOWAY v. STATE OF ARKANSAS" on Justia Law

Three subsidiaries of a major poultry company sought refunds for sales taxes paid on the rental of wooden shipping pallets used to deliver their food products. The pallets were rented from a supplier who retains ownership and reuses them after each delivery. The company argued that these pallets were an integral part of the products it sold, claiming that the pallet rentals should be exempt from sales tax under Arkansas’s sales-for-resale exemption, since the pallets were essential in delivering their goods to distributors and retailers.The Department of Finance and Administration denied the refund request. The company then sought review in the Washington County Circuit Court, which granted summary judgment in favor of the Department. The circuit court concluded that the pallet rentals did not qualify for the sales-for-resale exemption, determining that the pallets were merely a mechanism for delivery and not an integral part of the food products themselves.The Supreme Court of Arkansas reviewed the circuit court’s summary judgment de novo. It examined the relevant statutory provisions, including Ark. Code Ann. § 26-52-401(12), and prior case law addressing when items used in manufacturing or delivery become a recognizable integral part of the final product. Applying these standards, the Supreme Court held that the pallets are not an integral part of the chicken or other food products sold, as they do not become part of the product itself but are only used for delivery. The court affirmed the circuit court’s decision, holding that the pallet rentals are not tax-exempt sales for resale and denying the company’s refund claim. View "TYSON CHICKEN, INC. V. HUDSON" on Justia Law

On December 25, 2023, Maximo Hernandez was stabbed to death with both a knife and a Phillips-head screwdriver in his Batesville home. The victim and the appellant had previously been roommates, and evidence placed the appellant at the residence during the relevant timeframe. Blood was found throughout the home, including on the murder weapon and on doorknobs, with DNA analysis matching the appellant. Additionally, the appellant presented with unexplained injuries to his hand at a hospital shortly after the incident. Cellphone data contradicted the appellant’s statements about his whereabouts on the day of the murder.The Independence County Circuit Court denied the appellant's motion for a directed verdict, which had challenged the sufficiency of the evidence to prove purposeful murder. The jury convicted the appellant of first-degree murder and sentenced him to life imprisonment. The appellant argued on appeal that the evidence was insufficient to establish that he intentionally caused Hernandez’s death, claiming that the State had not excluded other reasonable hypotheses and that the presence of his DNA was consistent with his prior residence.The Supreme Court of Arkansas reviewed the case and applied the substantial evidence standard, viewing the evidence in the light most favorable to the State. The court held that the State presented substantial evidence from which the jury could conclude that the appellant purposely caused Hernandez’s death, including the number and nature of the stab wounds, the use of multiple weapons, and the appellant’s blood found throughout the scene. The court affirmed the conviction, finding the evidence sufficient to support the jury’s verdict and holding that the circuit court properly denied the motion for directed verdict. View "CANNALTE v. STATE OF ARKANSAS" on Justia Law

The case involves an individual who was convicted of first-degree murder and employing a firearm in the commission of the offense. The defendant and the victim had been in a declining romantic relationship, which culminated in the victim’s death by gunshot shortly after meeting with the defendant to retrieve her stolen cellphone. Surveillance footage captured the incident, and recordings included the victim calling out the defendant’s name prior to the shooting. Following the murder, the defendant sent messages indicating efforts to evade law enforcement and destroy evidence. He was apprehended after a standoff with police. The defendant was charged with capital murder and a firearm enhancement.During trial proceedings in the Crittenden County Circuit Court, a prospective juror’s comment about his employment at the county jail led to a discussion about potential bias, after which the juror was excused. The defendant moved for a mistrial, arguing that the juror’s statement prejudiced the jury pool by implying his incarceration, but the circuit court denied the motion, providing a curative explanation to the jury pool. The State also exercised peremptory strikes against four black prospective jurors, which the defendant challenged under Batson v. Kentucky, 476 U.S. 79 (1986), claiming racial discrimination. The circuit court found the State’s race-neutral explanations for the strikes credible and denied the Batson challenges.On appeal, the Supreme Court of Arkansas reviewed whether the circuit court abused its discretion in denying the motion for mistrial and whether it erred in overruling the Batson challenges. The Supreme Court held that the circuit court did not abuse its discretion in denying the mistrial, as any potential prejudice was adequately cured. The court also affirmed the circuit court’s findings that the State’s reasons for its peremptory strikes were race-neutral and not clearly against the preponderance of the evidence. The convictions were affirmed. View "SINGLETON v. STATE OF ARKANSAS" on Justia Law

Luis Ramirez was charged with serious offenses, including attempted capital murder, after allegedly participating in a drive-by shooting in March 2022. The State agreed to drop these charges if Ramirez successfully enlisted in the United States Marine Corps, characterizing this as a conditional agreement. Ramirez did not join the Marines and was later allegedly involved in another altercation with the original victim. The State then moved to reinstate the original charges based on Ramirez’s failure to fulfill the enlistment condition.The Benton County Circuit Court initially granted the State’s request to nolle prosequi the charges, recognizing the agreement was contingent on Ramirez’s enlistment. After the State sought to reinstate the charges due to Ramirez’s non-enlistment, Ramirez moved to dismiss, arguing for enforcement of the agreement. The circuit court granted his motion, finding Ramirez made a good-faith effort to join the Marines and was prevented from enlisting by the State’s actions. The court relied on principles of equitable enforcement and referenced rules concerning plea withdrawals and immunity agreements.The Supreme Court of Arkansas reviewed the case and held that the appeal was proper because it raised an important, unresolved legal question about the enforceability of agreements to nolle prosequi charges. The court concluded that ordinary contract principles apply to such agreements. It found the agreement was a unilateral contract, under which the State’s obligation not to prosecute arose only if Ramirez performed by enlisting in the Marines. Because Ramirez did not fulfill this condition, the State was entitled to reinstate charges. The circuit court’s dismissal was reversed, and the case was remanded for further proceedings. View "STATE OF ARKANSAS V. RAMIREZ" on Justia Law

Voters in Independence County, Arkansas, passed an ordinance requiring local elections to use hand-marked, hand-counted paper ballots. After about a year, the county quorum court repealed the ordinance, relying on state law. Bryan Norris and associated organizations sued county officials, challenging the quorum court’s authority to repeal the ordinance, claiming the state statute allowing such action was unconstitutional, and seeking to enforce the voter-adopted ordinance.The Independence County Circuit Court dismissed all claims, citing Act 975 of 2025, which purported to grant exclusive original jurisdiction over facial constitutional challenges to state statutes to the Arkansas Court of Appeals, rather than circuit courts. The County argued that the circuit court lacked subject-matter jurisdiction under this new law. Norris appealed, narrowing the issue to the constitutionality of Act 975.The Supreme Court of Arkansas reviewed the lower court’s dismissal de novo, as the issue involved a question of law. The Supreme Court held that Act 975 was unconstitutional. The Arkansas Constitution, specifically Amendment 80, vests circuit courts with original jurisdiction over all justiciable matters unless otherwise provided, and confines the Court of Appeals to appellate jurisdiction as determined by Supreme Court rule. The General Assembly’s power to establish jurisdiction is limited by the Constitution’s explicit assignments. Act 975’s attempt to strip circuit courts of original jurisdiction and confer it on the Court of Appeals—an appellate court—contradicted the Constitution’s plain language. The Supreme Court of Arkansas concluded that Act 975 is unconstitutional, reversed the circuit court’s dismissal, and remanded the case for further proceedings. View "NORRIS V. INDEPENDENCE COUNTY, ARKANSAS" on Justia Law

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