Justia Arkansas Supreme Court Opinion Summaries

Kent Parris was apprehended after selling fentanyl, methamphetamine, and drug paraphernalia to a confidential informant during a law enforcement sting operation near a church. Following the transaction, Parris fled in his vehicle but was eventually stopped by officers, who found marked bills and various drugs on his person and in his car. During a search along the route of the brief vehicle chase, police recovered a bag containing methamphetamine and a backpack with a loaded handgun and additional pills. At trial, evidence included audio recordings, body camera footage, physical drug evidence, and the items seized from Parris and the scene.The Arkansas County Circuit Court jury convicted Parris on multiple counts: possession of fentanyl and cocaine with intent to deliver, possession of drug paraphernalia to manufacture, delivery of methamphetamine and fentanyl, simultaneous possession of drugs and firearms, and theft by receiving a firearm. The jury imposed consecutive sentences totaling life plus 185 years, with an additional concurrent ten-year enhancement for committing drug crimes within one thousand feet of a church. Parris challenged the sufficiency of the evidence for several convictions and contested the enhancement.The Supreme Court of Arkansas reviewed the case and affirmed all convictions and the sentence enhancement except for the theft-by-receiving conviction. The court held that substantial evidence supported the drug-related convictions and the simultaneous possession charge, relying on both direct and circumstantial evidence. However, regarding theft by receiving, the court found that the only evidence the firearm was stolen was inadmissible hearsay from a police officer referencing a report. Concluding there was insufficient evidence that the firearm was stolen property, the court reversed the theft-by-receiving conviction and remanded the case to the circuit court for a new sentencing order. The remaining convictions and enhancements were affirmed. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

A man was convicted by a jury of raping his then-girlfriend’s 14-year-old daughter, following evidence that included sexually explicit electronic messages he sent to the minor, testimony from the victim about the assault, and testimony from another of his daughters describing similar sexual abuse. The victim disclosed the assault to her mother immediately after it occurred, but her mother did not initially believe her or contact authorities. Several years later, the mother received messages from the defendant describing further sexual abuse of his other children; these messages ultimately led to the involvement of law enforcement and the defendant’s arrest and prosecution.The Garland County Circuit Court admitted the contested electronic messages into evidence, finding sufficient authentication through the testimony of the recipients. The court also allowed the defendant’s other daughter to testify to similar abuse under the “pedophile exception” to Arkansas Rule of Evidence 404(b), determining the testimony was more probative than prejudicial. The defendant moved for a continuance after being charged with additional sexual offenses days before trial, but the circuit court denied the motion, finding he was able to assist his counsel. After conviction, the court sentenced him to life in prison.On appeal to the Supreme Court of Arkansas, the defendant challenged the sufficiency of the evidence, the admission of the electronic messages and other-acts testimony, the denial of the continuance, and the constitutionality of his life sentence. The Supreme Court of Arkansas affirmed the conviction and sentence. It held that substantial evidence supported the jury’s finding that the defendant was in a position of authority over the victim as required by statute; the circuit court did not abuse its discretion in its evidentiary rulings or in denying the continuance; and the life sentence for child rape was not unconstitutional under either the Eighth Amendment or the Arkansas Constitution. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

During a law enforcement sting operation, the defendant sold fentanyl, methamphetamine, and drug paraphernalia near a church to a confidential informant. After the transaction, officers attempted to stop him, leading to a brief chase. The defendant was apprehended, and police recovered marked bills, various drugs, digital scales, and, along the route of the chase, a clear bag containing methamphetamine and a black bag containing a handgun and pills. Physical evidence and video footage of the transaction were introduced at trial. The pills were confirmed to contain fentanyl, and the cocaine found was packaged in a manner consistent with distribution.The Arkansas County Circuit Court jury convicted the defendant of multiple drug offenses, simultaneous possession of drugs and a firearm, and theft by receiving a firearm. He was sentenced to life plus an additional 185 years, with sentences to run consecutively, and a ten-year enhancement for drug crimes near a church. The defendant appealed, challenging the sufficiency of the evidence on all convictions and the sentence enhancement.The Supreme Court of Arkansas reviewed the evidence in the light most favorable to the verdict and found substantial evidence supporting all the drug-related convictions and the enhancement. The court held that circumstantial evidence sufficiently linked the defendant to the drugs and firearm found during the chase, allowing for the simultaneous possession conviction. However, the court determined there was not substantial evidence to support the theft-by-receiving conviction because the only proof the firearm was stolen was inadmissible hearsay testimony from an officer regarding a database entry. The Supreme Court of Arkansas affirmed all convictions except the theft-by-receiving conviction, which it reversed and remanded for entry of a new sentencing order. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury of raping the 14-year-old daughter of his then-live-in girlfriend. The evidence included testimony that he sent the victim sexually explicit messages, gave her alcohol, and raped her while she was intoxicated. Several years later, after the appellant described to the victim’s mother in a series of electronic messages how he had raped his own daughters, the mother reported the abuse. Further testimony was provided by one of the appellant’s daughters, who described a longstanding pattern of sexual abuse and grooming by the appellant. The appellant was sentenced to life in prison.Prior to this appeal, the Garland County Circuit Court presided over the trial. The appellant moved for a continuance after being charged in a separate case with raping another of his daughters, arguing that the new charges impaired his ability to participate in his defense. The circuit court denied the motion, finding the appellant was able to assist his counsel. The court also overruled the appellant’s objections to the admission of explicit electronic messages and testimony from his daughter describing other uncharged sexual offenses, concluding that authentication and evidentiary standards were met. The jury convicted the appellant and imposed a life sentence.On review, the Supreme Court of Arkansas addressed the appellant’s challenges to both his conviction and sentence. The court held that substantial evidence supported the jury’s finding that the appellant was in a position of authority over the victim as required by Arkansas law. The court found no abuse of discretion in the denial of the continuance or in the admission of the challenged evidence, holding that the evidence was properly authenticated and the testimony of the appellant’s daughter was admissible under the “pedophile exception” to Arkansas Rule of Evidence 404(b). The court further held that the life sentence did not violate the Eighth Amendment or the Arkansas Constitution. The judgment was affirmed. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

A seventeen-year-old was charged in the St. Francis County Circuit Court with three counts of capital murder and one count of felony theft after his mother, her boyfriend, and his twelve-year-old sister were found shot to death in their home. The evidence included the recovery of the victims’ vehicle, a firearm, gunshot residue on the accused’s clothing, and DNA evidence. The accused denied involvement but was contradicted by testimony from his four-year-old sister and other evidence. The defense presented testimony about his background, mental health, and the potential for rehabilitation.After the accused moved to transfer the case to the juvenile division, the St. Francis County Circuit Court held a hearing and denied the motion. On interlocutory appeal, the Arkansas Court of Appeals found that the circuit court had failed to address a required statutory factor and remanded for additional findings. The circuit court entered an amended order again denying transfer. The accused then appealed to the Arkansas Supreme Court.The Arkansas Supreme Court first ruled that the accused's constitutional challenge to Arkansas Code Annotated section 9-27-318 was not preserved for appellate review because it was not raised in the circuit court. The court also held that the circuit court properly exercised subject-matter jurisdiction. Reviewing the denial of transfer for clear error, the Arkansas Supreme Court concluded that the amended order adequately addressed all statutorily required factors, gave appropriate weight to the seriousness and violent nature of the offenses, and was not clearly erroneous. The Supreme Court affirmed the circuit court’s denial of the motion to transfer the case to the juvenile division. View "ROLFE v. STATE OF ARKANSAS" on Justia Law

Keeling Grubb, acting as president and CEO of Eureka Gun and Pawn, LLC, sought a conditional-use permit (CUP) from the City of Eureka Springs to operate the business as a gun and pawn shop. Grubb submitted the application in May 2023, but the City’s Planning Commission denied it at a special meeting, and the denial was subsequently upheld by the Eureka Springs City Council. After these denials, Grubb and Eureka Gun filed a complaint in Carroll County Circuit Court, challenging the City’s actions and advancing multiple constitutional and statutory claims related to due process, equal protection, property rights, freedom of association and speech, as well as the right to bear arms.In Carroll County Circuit Court, the bench trial was expressly limited to count one of the complaint: an appeal of the City Council’s administrative decision denying the CUP. The remaining claims were reserved for future resolution. During trial, evidence was presented on the nature of the business and community views, but the primary issue was whether Eureka Gun was entitled to a CUP under the City's ordinance. The circuit court denied the appellants’ motion for partial summary judgment and granted the City’s motion for directed verdict, finding that Eureka Gun was not entitled to the permit. Additionally, the court ruled that Arkansas Code Annotated § 14-16-504(b)(1)(A) did not apply to the commercial sale of firearms.The Supreme Court of Arkansas reviewed the appeal. It held that the orders appealed from were not final because the circuit court had only adjudicated one of multiple claims, leaving the others pending, and no Rule 54(b) certificate was issued to permit an immediate appeal. Consequently, the Supreme Court dismissed the appeal without prejudice for lack of a final order and declined to address the merits. View "EUREKA GUN AND PAWN, LLC V. THE CITY OF EUREKA SPRINGS" on Justia Law

In this case, two licensed medical marijuana businesses in Arkansas challenged the validity of twenty-eight legislative amendments made by the Arkansas General Assembly to Amendment 98 of the Arkansas Constitution, which established a framework for medical marijuana use in the state. The businesses argued that these amendments were unconstitutional because they had not been submitted for voter approval, as they claimed was required, and that the amendments were not germane to the pertinent section as required by the constitutional language.The Pulaski County Circuit Court agreed with the plaintiffs, relying on the precedent set by Arkansas Game & Fish Commission v. Edgmon, and ruled that the General Assembly lacked authority to amend a voter-initiated constitutional amendment without submitting those amendments to a public vote. The court also found that the legislative amendments were not germane to section 23 of Amendment 98 and were therefore unconstitutional and void. The State of Arkansas appealed this ruling.The Supreme Court of Arkansas reviewed the case and reversed the circuit court’s decision. The court held that Article 5, section 1 of the Arkansas Constitution does grant the General Assembly authority to amend voter-initiated laws, including initiated constitutional amendments, by a two-thirds vote of both legislative chambers. The court explicitly overruled Arkansas Game & Fish Commission v. Edgmon, finding its reasoning inconsistent with the plain constitutional text. Additionally, the court determined that the word “section” in section 23(a) of Amendment 98 should be interpreted as “amendment,” so the germaneness requirement applies to the amendment as a whole. Consequently, the Supreme Court of Arkansas reversed and dismissed the lower court’s ruling. View "STATE OF ARKANSAS v. GOOD DAY FARM ARKANSAS, LLC" on Justia Law

Reggie Matthews was convicted of capital murder for killing Tiana Robinson, with whom he had a tumultuous and abusive relationship. In the year leading up to Robinson’s death, Matthews demonstrated escalating threats, including refusing to leave Robinson’s home, making armed threats, and being reported for prowling near her residence shortly before the murder. On September 6, 2023, at a barbecue in Osceola, Arkansas, Matthews arrived, pursued Robinson as she attempted to flee, and shot her multiple times in the back. Multiple eyewitnesses identified Matthews as the shooter. After the crime, Matthews was arrested and made statements to police following a brief invocation of his right to counsel.In the Mississippi County Circuit Court, Matthews challenged his conviction on several grounds. He argued that the evidence was insufficient to support the verdict, that his statements to police should have been suppressed after he invoked his right to counsel, that a police officer’s unsolicited reference to a bystander’s identification violated a pretrial order and required a mistrial, and that allowing an officer to testify about Matthews’s interrogation violated the best-evidence rule. The circuit court denied his motions for a directed verdict, suppression, and a mistrial, and allowed the officer’s testimony. Matthews was found guilty and sentenced to life without parole.On appeal, the Supreme Court of Arkansas reviewed each of Matthews’s claims. The court held that substantial evidence supported the jury’s verdict, as multiple eyewitnesses identified Matthews as the shooter and his actions demonstrated premeditation and deliberation. The court determined that Matthews’s post-arrest statements were admissible because he reinitiated communication with police after requesting counsel. The court also found no abuse of discretion in denying a mistrial and held that the best-evidence rule was not violated since the recording was admitted. The Supreme Court of Arkansas affirmed Matthews’s conviction and sentence. View "MATTHEWS V. STATE OF ARKANSAS" on Justia Law

A teenage boy was found delinquent for committing second-degree sexual assault against his five-year-old half-niece. On Thanksgiving Day 2022, while staying at the victim’s home, the boy digitally penetrated the child’s rectum on a living room couch. The incident ended when the victim’s mother entered the room. Later that day, the child disclosed the assault to her parents, who contacted police and took her to the hospital. A sexual-assault nurse found no observable injury but collected rectal swabs and underwear, both of which tested positive for male DNA, though not in sufficient quantity to identify a specific individual. About a week later, the victim gave a recorded forensic interview detailing the assault.The State of Arkansas filed a delinquency petition in the Saline County Circuit Court, Juvenile Division. At the bench trial, the victim testified about the assault. The defense sought to impeach her credibility by playing selected segments of her prior forensic interview, suggesting inconsistencies. The State moved to admit the full recording under Arkansas Rule of Evidence 803(25), arguing it was necessary for context. The circuit court admitted the entire recording after in camera review, found the victim credible, and adjudicated the boy delinquent for second-degree sexual assault.On appeal, the Supreme Court of Arkansas reviewed the sufficiency of the evidence and the admission of the entire recorded interview. The court held that substantial evidence, including the victim’s testimony, corroboration by her parents, and the DNA evidence, supported the delinquency adjudication. The court further held that, although Rule 803(25) did not authorize admitting the full recording, it was admissible for rehabilitation and context in light of the defense’s impeachment attempt. The Supreme Court of Arkansas affirmed the adjudication. View "MINOR CHILD v. STATE OF ARKANSAS" on Justia Law

The case concerns the December 26, 2020, shooting death of Shaletian Larry. The defendant, Lazarus Reaves, and Larry were in a relationship marked by repeated abuse, as shown by text messages, witness testimony, and prior police involvement. On the day of the incident, after an argument and an altercation in the car, several witnesses observed Larry attempting to escape from her moving vehicle before Reaves shot her in the back and left her on the roadside. Physical evidence, including blood in the car and a firearm linked to Reaves and Larry, supported the prosecution’s case.The Washington County Circuit Court convened a jury trial. The State presented its evidence, after which Reaves moved for a directed verdict on the capital murder and tampering charges, arguing insufficient proof of premeditation. The motion was denied by the circuit court judge. Reaves did not present any evidence in his defense. The jury found him guilty of both charges, and he was sentenced to life imprisonment without parole for capital murder and a concurrent six-year term for tampering with evidence.On appeal, the Supreme Court of Arkansas reviewed whether the evidence was sufficient to support the conviction for capital murder, specifically the element of premeditation and deliberation. The court held that, even with only a single gunshot wound, substantial evidence existed to support the jury’s finding of premeditated and deliberated intent to kill, based on the circumstances of the crime and Reaves’s prior conduct and threats. The court affirmed the conviction and the judgment of the Washington County Circuit Court. View "LAZARUS REAVES V. STATE OF ARKANSAS" on Justia Law