Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the order of the circuit court granting Plaintiffs' motion for class certification in this action alleging that Defendant, which leased with Plaintiffs to drill and sell hydrocarbons from the leased property, improperly suspended royalty payments, holding that the requirements of numerosity and superiority were met. The complaint alleged that the royalty payments were suspended in an effort by Defendant to recoup improper deductions. Plaintiffs moved for class certification, which the trial court granted. Defendant appealed, arguing that Plaintiffs failed to satisfy the numerosity and superiority requirements. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in determining that the numerosity and superiority requirements were satisfied in this case. View "Stephens Production Co. v. Mainer" on Justia Law

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The Supreme Court affirmed the order of the circuit court denying Appellant's petition for writ of error coram nobis, holding that the circuit court did not abuse its discretion in denying the petition. Appellant pled guilty to one count of rape. In his coram nobis petition, Appellant alleged, among other things, that the guilty plea was coerced. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding (1) certain exhibits Appellant included in his brief to support his claim on appeal that were not included in Appellant's petition to the circuit court or otherwise contained in the record are removed from consideration; and (2) under the circumstances, the circuit court did not abuse its discretion in denying Appellant's petition. View "Kain v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the circuit court's denial of Appellant's pro se petition for writ of habeas corpus, holding that none of Appellant's claims were sufficient to demonstrate that the trial court lacked jurisdiction or that the judgment of conviction was invalid on its face. In 1991, Appellant was found guilty of capital murder and was sentenced to life imprisonment without parole. In 2018, Appellant filed his petition for a writ of habeas corpus, arguing, among other things, that new evidence had emerged exonerating him of the crime and that material evidence was withheld at his trial in violation of Brady v. Maryland, 373 U.S. 83 (1963). The circuit court found that the habeas petition was untimely and without merit. The Supreme Court affirmed, holding that Appellant failed to make a showing that the face of the judgment was invalid or to present evidence of probable cause to believe he was being illegally detained. View "McArthur v. State" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the circuit court's order granting summary judgment to Defendant, Dr. Leslie Smith, based on quasi-judicial immunity, holding that Defendant was entitled to quasi-judicial immunity because the suit sought to hold him liable for his performance of functions integral to the judicial process. In 2011, Kenneth McFadden stabbed Virgil Brown to death in their shared apartment. At the time of the murder, McFadden was in custody of Greater Assistance to Those in Need, Inc. as part of his conditional release under Act 911 of 1989 and was serving psychiatric treatment by Dr. Smith. Plaintiff, Brown's daughter, filed this action against Dr. Smith on behalf of her father's estate, claiming that Dr. Smith's alleged failure to provide adequate treatment to McFadden rendered him liable for her father's death. The circuit court concluded that Dr. Smith was entitled to immunity because his treatment of McFadden arose solely from the conditional release order and was within the scope of that order. The Supreme Court affirmed, holding that to the extent Dr. Smith's actions fell within the scope of the court's order he was entitled to quasi-judicial immunity. View "Martin v. Smith" on Justia Law

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The Supreme Court reversed the order of the circuit court dismissing Appellant's petition for judicial review of an administrative decision by the director of the Arkansas State Police, holding that the circuit court erred in concluding that the petition was barred by the State's sovereign immunity from suit. Appellant, a California resident, submitted an application to the state police to become licensed as a private investigator in Arkansas. The application was denied, and Appellant filed an administrative appeal. Colonel William J. Bryant, in his capacity as the director of the state police, found that Appellant was ineligible to receive a license due to his prior convictions. The circuit court concluded that Appellant's petition for judicial review was barred by the State's sovereign immunity. The Supreme Court reversed, holding that the State's sovereign immunity from suit did not apply to this proceeding. View "Hackie v. Bryant" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the order of the circuit court dismissing his pro se petition for a writ of habeas corpus, which rendered his motions filed in connection with the appeal moot, holding that Appellant failed to demonstrate that the sentence was illegal on its face or the trial court lacked jurisdiction. Appellant pleaded guilty to attempted first-degree murder and first-degree battery and was sentenced to 540 months' imprisonment. In his habeas petition, Appellant argued that the trial court failed to pronounce sentence in open court at the conclusion of the plea hearing in violation of Ark. Code Ann. 16-90-106(d). The circuit court denied postconviction relief. The Supreme Court affirmed, holding that Appellant's sentences were not illegal on the face of the judgment, and there was no showing that the trial court lacked jursidiction to impose the sentences. View "Johnson v. Kelley" on Justia Law

Posted in: Criminal Law

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The Supreme Court reversed the order of the circuit court granting Plaintiff's motion for summary judgment and finding that the City of Fort Smith and its directors violated the open-meeting provisions of the Arkansas Freedom of Information Act (FOIA) when three of the city directors and the city administrator exchanged emails relating to city business, holding that the email communication did not violate the open-meeting provisions set forth in Ark. Code Ann. 25-19-106. Specifically, the Court held (1) FOIA's open-meeting provisions apply to email and other forms of electronic communication between governmental officials just as they apply to in-person or telephonic conversations; but (2) the emails in this case were only background information and non-decisional information sharing, and therefore, there was no violation of the of the open-meeting provisions. View "City of Fort Smith v. Wade" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellants' motion to dismiss Appellees' complaint on sovereign immunity grounds but reversed the circuit court's grant of the temporary injunction, holding that the injunction failed to comply with Ark. R. Civ. P. 65. Appellees, landowners whose only property was an unpaved road that crossed property owned by the Arkansas Game & Fish Commission (AGFC), brought this action alleging that AGFC had blocked their access to their property by installing a locked gate over the road. Appellees sought enforcement through injunctive relief. The circuit court denied AGFC's motion to dismiss, concluding that AGFC was not entitled to sovereign immunity, and ordered AGFC to immediately provide a key to the locked gate and allow Appellees vehicular access using the road. The Supreme Court held (1) because the complaint alleged that AGFC acted illegally or in an ultra vires manner the complaint was not subject to dismissal under the doctrine of sovereign immunity; and (2) the temporary injunction must be dissolved for failure to comply with Rule 65. View "Arkansas Game & Fish Commission v. Heslep" on Justia Law

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In this divorce case, the Supreme Court affirmed on direct appeal the order of the circuit court on remand from the Supreme Court but reversed and remanded on cross appeal, holding that the circuit court erred in calculating the amount Nancy Moore was ordered to reimburse John David Moore (David) for his payments on a parcel of real property referred to as "Granny's Place." When this case was first before the Supreme Court the Court reversed the circuit court's division of certain property and award of alimony and remand. David appealed from the circuit court's order on remand, and Nancy cross-appealed. The Supreme Court held that the circuit court (1) did not err in dividing the marital property unequally under the circumstances of this case; (2) did not clearly err in valuing and dividing the martial livestock; (3) did not err in holding David in contempt; but (4) erred by awarding David his request for reimbursement for payments he made toward the principal indebtedness on Granny's Place. View "Moore v. Moore" on Justia Law

Posted in: Family Law

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The Supreme Court affirmed the order of the circuit court finding attorney Jonathan Streit in contempt of court and assessing a $100 fine, holding that substantial evidence supported the court's decision that Streit's actions displayed a lack of regard for the court's integrity and demonstrated disrespect. Streit appeared before the circuit court on a petition for permanent guardianship. At the hearing, the circuit court noted several deficiencies in the case file. The circuit court was unwilling to let the matter to proceed without compliance with the statutory requirements, and Streit argued that the circuit court took issue with him because he successfully reversed the circuit court in a separate case. The circuit court then found Streit in contempt of court and assessed a fine. The Supreme Court affirmed, holding that substantial evidence supported the court's decision to hold Streit in contempt. View "Streit v. State" on Justia Law