Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Arkansas Supreme Court
Prock v. Bull Shoals Boat Landing
Appellant was injured while working for Employer. Following the accident, a drug test on Appellant came back positive. Appellant sought workers’ compensation benefits. An administrative law judge found that Appellant was entitled to benefits, concluding that he met his burden of proving that his accidental work incident was not substantially occasioned by the use of drugs. The Arkansas Workers’ Compensation Commission reversed, determining that Appellant did not rebut the presumption that his accident was substantially occasioned by his use of illegal drugs. The Supreme Court reversed and remanded to the Commission for a determination of benefits, holding that substantial evidence did not support the Commission’s finding that Appellant failed to rebut the presumption by a preponderance of the evidence.
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Nelson v. State
In 1972, Appellant pled guilty to murder in the first degree and was sentenced to life imprisonment. In 2012, Appellant filed a petition for writ of error coram nobis, asserting that his guilty plea was not voluntarily entered because it was the product of coercion and because his counsel had operated under a conflict of interest at the time the plea was entered. The circuit court denied Appellant’s petition. The Supreme Court affirmed, holding that Appellant’s claims were actually predicated on allegations of ineffective assistance of counsel, and his allegations were not cognizable in a proceeding for error coram nobis. View "Nelson v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Murry v. Hobbs
In 2005, Appellant pleaded guilty to charges of theft by receiving, being a felon in possession of a firearm, and possession of a controlled substance with intent to deliver. Appellant received a ten-year suspended sentence on each count, but, in 2009, the trial court revoked Appellant’s suspended imposition of sentence for Appellant’s failure to meet the conditions under which the sentence was suspended. In 2013, Appellant filed a petition for writ of habeas corpus alleging that he was not afforded effective assistance of counsel when he entered his guilty plea and that the 2005 ten-year suspended imposition of sentence was an illegal sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant did not establish a basis for a writ of habeas corpus to issue.
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Jones v. Jones
Myra and Charles Jones married in 1992. In 2011, Myra filed a complaint for divorce. After the circuit court entered a divorce decree, Charles appealed, contesting the circuit court’s division of property in four respects. The Supreme Court affirmed, holding that the circuit court did not err (1) by not awarding Charles a financial benefit in a home that Myra purchased before the marriage; (2) in its division of the parties’ vehicles; (3) by giving Myra an interest in Charles’s life-insurance policies; and (4) not imposing a constructive trust for the return of land in which Charles had deeded an interest to Myra. View "Jones v. Jones" on Justia Law
Posted in:
Arkansas Supreme Court, Family Law
Edmisten v. Bull Shoals Landing
Appellant was injured at work and taken to the hospital, where he tested positive for marijuana. The Arkansas Workers’ Compensation Commission denied Appellant’s claim for benefits based on its finding that, after the accident, Appellant tested positive for illegal drugs and thatAppellant failed to rebut the statutory presumption that the accident was substantially occasioned by his drug use. The Supreme Court reversed and remanded the Commission’s decision, holding that substantial evidence did not support the finding that Appellant failed to rebut the presumption that his accident was not substantially occasioned by his use of illegal drugs. View "Edmisten v. Bull Shoals Landing" on Justia Law
Dixon v. State
After a jury trial, Appellant was found guilty of capital felony murder and sentenced to life imprisonment without the possibility of parole. After Appellant’s conviction was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, alleging ineffective assistance of trial counsel. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding that (1) some of Appellant’s claims were conclusory and raised for the first time on appeal and thus not subject to review; and (2) the remainder of Appellant’s claims of error were without merit. View "Dixon v. State" on Justia Law
Williford v. State
In 1987, Petitioner pleaded guilty in two cases to two counts of burglary and two counts of theft of property. Petitioner was placed on ten years’ probation. In 2010, Petitioner filed a petition for writ of error coram nobis in the two cases, which the trial court denied. Petitioner subsequently filed a motion for reconsideration, which was denied. Petitioner subsequently sought leave to proceed with a belated appeal from the denial of his petition for writ of error coram nobis. The Supreme Court dismissed Petitioner’s motion, holding that because Petitioner had served his sentence by the time he filed the petition, his claim was moot.
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Posted in:
Arkansas Supreme Court, Criminal Law
Turner v. State
After a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to life imprisonment. A notice of appeal was filed, but Appellant’s appellate counsel, a full-time public defender, asked that she be relieved as counsel on the ground that she was ineligible for compensation for services as appellate counsel. The Supreme Court granted counsel’s motion to be relieved because, where counsel was a full-time public defender with a full-time, state-funded secretary, counsel was not entitled to be paid for services in this appeal under Ark. Code Ann. 19-4-1604(b)(2)(B).
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Posted in:
Arkansas Supreme Court, Criminal Law
Travis v. State
After a jury trial, Petitioner was found guilty of capital murder and aggravated robbery and sentenced to an aggregate term of life without parole. The Supreme Court affirmed on appeal. Petitioner later filed a petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he may proceed with a petition for writ of error coram nobis, asserting trial error and complaining about the length of his sentence. The Supreme Court denied the petition, holding that Petitioner’s assertions were not sufficient to demonstrate any extraordinary circumstances warranting reopening the direct appeal of the judgment of conviction in this case. View "Travis v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Thompson v. State
After a jury trial, Appellant was found guilty of first-degree murder, among other offenses. Appellant was sentenced to life imprisonment for the murder conviction. A timely notice of appeal was filed, but the attorney appointed to represent Appellant on appeal filed a motion to withdraw as counsel and a no-merit brief. Appellant submitted a pro se response, and the State responded. The Supreme Court stayed appellate counsel’s motion to withdraw and ordered rebriefing because counsel failed fully to comply with the requirements of Anders v. California and Ark. Sup. Ct. R. 4-3(k). View "Thompson v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law