Justia Arkansas Supreme Court Opinion Summaries

In 1989, Appellee pled guilty to one count of first-degree sexual abuse. In 2013, Appellee filed a motion asking the circuit court to terminate his obligation to register as a sex offender. The circuit court granted the motion and denied the State’s subsequent motion for reconsideration. The State appealed, contending that the circuit court clearly erred in concluding that Appellee was not likely to pose a threat to the safety of others and therefore could be relieved of his obligation to register as a sex offender. The Supreme Court affirmed the circuit court’s decision terminating Appellee’s obligation to register as a sex offender, holding that the circuit court did not clearly err in concluding that Appellee had proved by a preponderance of the evidence that he was not likely to pose a threat to the safety of others. View "State v. Khabeer" on Justia Law

Appellee, as special administrator of the estate of Rufus Owens and on behalf of the wrongful death beneficiaries of Owens, filed a lawsuit against Pine Hills Health and Rehabilitation, LLC and others for injuries Owens sustained during his care and treatment at Pine Hills. Appellants moved to dismiss the complaint and compel arbitration pursuant to an arbitration agreement. Appellee argued that the arbitration agreement was unenforceable because there was no evidence of mutual assent where the agreement was signed by Appellee as the "responsible party" but did not bear the signature of a representative of Pine Hills. The circuit court denied the motion to compel arbitration. The Supreme Court affirmed, holding that there was no objective evidence of mutual assent, and therefore, the arbitration agreement was unenforceable. View "Pine Hills Health & Rehab., LLC v. Matthews" on Justia Law

Truck Insurance Exchange (TIE) issued an apartment-owners insurance policy to appellant Jeanne Estates Apartments (JEA) that became effective in 1998. In 2006, Farmers Insurance Exchange (FIE) renewed the policy and continued to provide coverage. In 2008 and 2010, JEA became involved in three underlying lawsuits, which involved several appellants. JEA submitted claims for coverage to TIE/FIE in regard to those cases. TIE/FIE filed a complaint requesting that the circuit court declare that they owed no coverage to any person for any of the alleged misconduct which formed the basis of the claims in the underlying lawsuits and that they had no duty to provide a defense to any person or entity who was a defendant in the underlying lawsuits. The circuit court granted summary judgment in favor of TIE/FIE. The Supreme Court affirmed, holding that the apartment-liability contract issued by TIE/FIE did not provide an insured coverage for the type of harm alleged by the plaintiffs in the underlying suit. View "Kolbek v. Truck Ins. Exch." on Justia Law

After a jury trial, Appellant was convicted of three counts of rape and sentenced to forty years’ imprisonment on each count, with the sentences to be served concurrently. On appeal, Appellant argued that the circuit court erred (1) in permitting the State to introduce pornographic images from Appellant’s computer without sufficient evidence that he viewed the pornography; (2) in admitting the pornographic images under Ark. R. Evid. 404(b); and (3) in concluding that the probative value of the evidence outweighed its prejudicial effect under Ark. R. Evid. 403. The Supreme Court affirmed, holding that any error in the admission of the images by the circuit court was harmless. View "Johnston v. State" on Justia Law

In 2010, Appellant was found guilty by a jury of delivery of cocaine and sentenced to 900 months’ imprisonment. The trial court vacated Appellant’s sentence. Appellant was subsequently resentenced pursuant to a negotiated guilty plea, and a sentence of 420 months’ imprisonment was imposed. The 2012 sentencing order reflected that Appellant received 805 days of jail-time credit. In 2013, Appellant filed a motion asserting that, in the 2012 sentencing order, the trial court erroneously denied him the benefit of 785 days of earned credit for meritorious good time. The trial court denied the motion. The Supreme Court dismissed Appellant’s appeal, holding (1) Appellant’s request for relief was directed toward the calculation of his accrual of meritorious good time, which was a matter of parole eligibility to be determined by the Arkansas Department of Correction; and (2) to the extent that Appellant’s claim could be construed as one for modification of his sentence, the motion was untimely filed. View "Green v. State" on Justia Law

After a jury trial, Appellant was found guilty of three counts of rape and one count of attempted rape of a minor. Appellant subsequently filed a timely pro se petition for postconviction relief, alleging ineffective assistance of counsel as well as trial errors based on the admission of a coerced confession, a violation of the prohibition against double jeopardy, and the filing of a defective information. The trial court denied the petition without a hearing. The Supreme Court dismissed Appellant’s appeal and declared moot the motions Appellant filed in relation to the appeal, holding (1) trial counsel did not provide constitutionally defective assistance; and (2) Appellant was not entitled to relief on his remaining allegations. View "Dodge v. State" on Justia Law

After a jury trial in 2001, Appellant was found guilty of first-degree murder and sentenced to an aggregate term of 540 months’ imprisonment. In 2012, Appellant filed a pro se petition for writ of habeas corpus pursuant to Act 1780 of 2011 as amended, asserting that, despite his confession to the crime during the investigation, scientific testing would show his actual innocence. The circuit court denied the petition, concluding that Appellant failed to rebut the presumption against timeliness. The Supreme Court affirmed, holding that Appellant did not establish good cause for the approximate eleven-year delay in filing his petition, and therefore, the circuit court did not err in denying Appellant’s petition without a hearing. View "Biggs v. State" on Justia Law

A police officer stopped Defendant for driving with a defective passenger taillight. The officer subsequently arrested Defendant and charged him with driving while intoxicated (DWI), among other offenses. Defendant filed a motion to suppress, arguing that there was no probable cause for the initial traffic stop. The circuit court denied the motion, concluding that there was reasonable cause for the traffic stop. After a jury trial, Defendant was convicted of refusal to submit to a chemical test but was acquitted of the DWI charge. Defendant appealed the denial of his motion to suppress, arguing that because there is no Arkansas statute prohibiting a cracked taillight, the officer did not have probable cause to stop his vehicle. The Supreme Court affirmed, holding (1) the fact that Defendant’s taillight was visibly broken was sufficient probable cause to believe that he may have committed a traffic violation; and (2) therefore, the circuit court correctly concluded that there was probable cause for the officer to stop Defendant. View "Robinson v. State" on Justia Law

After a jury trial, Petitioner was convicted of aggravated assault on a family or household member, among other charges. The court of appeals reversed and remanded. On remand, Petitioner sought postconviction relief under Ark. R. Crim. P. 37, arguing that his counsel provided ineffective assistance. The circuit court denied Hayes’s petition. Petitioner appealed from that ruling and then filed a motion to reconsider. The Supreme Court affirmed, holding (1) if any of Petitioner’s allegations were not ruled on by the circuit court, his failure to seek a writ of mandamus barred further action; and (2) the circuit court did not err in finding that Petitioner was not prejudiced by any error on the part of trial counsel. View "Hayes v. State" on Justia Law

After a jury trial, Appellant was found guilty of capital murder and sentenced to life imprisonment without parole. After the conviction was affirmed on appeal and Appellant unsuccessfully filed a petition for writ of habeas corpus, Appellant filed a second petition for habeas relief, alleging that his counsel provided ineffective assistance and that he was being illegally detained. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief because he failed to provide any factual support for his allegations, and the circuit court did not err in failing to hold a hearing on the petition. View "Buchanan v. Hobbs" on Justia Law