Justia Arkansas Supreme Court Opinion Summaries

Following the bankruptcy of BioBased Technologies, LLC, certain members of BioBased (Appellants) brought an action against other members, the members’ lawyers, and the managers of the corporation for fraud, breach of duty to disclose company information, conversion of membership interest, civil conspiracy, and breach of contract. The circuit court granted summary judgment on some claims, dismissed some claims, and found that the remainder of the claims were barred by collateral estoppel and res judicata. The Supreme Court reversed, holding (1) the circuit court erred in granting summary judgment on Appellants’ claims for fraud, breach of duty to disclose company information, and conversion of membership interest claims based on Appellants’ lack of standing, as Appellants had standing to assert their claims; (2) the circuit court erred in granting summary judgment on Appellants’ fraud claim against certain defendants on the basis that Appellants “failed to meet proof with proof” to show that the defendants made false representations of fact; (3) the circuit court erred in dismissing claims for lack of subject-matter jurisdiction; and (4) the circuit court erred in concluding that the bankruptcy proceeding had res judicata or collateral estoppel effect on Appellants’ state-law claims. Remanded. View "Muccio v. Hunt" on Justia Law

Mother and Father were divorced in 1999, and the circuit court granted primary custody of the parties’ three minor children to Mother. The circuit court later awarded custody of one of the parties’ children to Father and awarded child support and reimbursement of medical expenses to Father. Mother appealed, arguing, among other things, that the circuit court abused its discretion in granting Father’s objection to discovery requests regarding his financial condition, income, and assets. The Supreme Court reversed, holding that the circuit court abused its discretion in granting Father’s objection to Mother’s discovery request. Remanded with instructions for the circuit court to reconsider Mother’s request in light of her argument that the discovery request was relevant to the issue of child support. View "Hill v. Kelly" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder, committing a terroristic act, and being a felon in possession of a firearm. Appellant subsequently filed a petition for writ of habeas corpus, apparently contending that the trial court acted without authority and in violation of the state and federal constitutions by modifying the sentence recommended by the jury to add a consecutive sentence for a firearm enhancement. The circuit court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted the motions filed in relation to the appeal because the judgment-and-commitment order reflected the sentence fixed by the jury and ordered by the trial court. View "Frost v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, contending that his sentence was unconstitutional because the trial court admitted his prior juvenile-delinquency adjudication during the sentencing phase as a basis for sentencing him as a habitual offender. The circuit court denied habeas relief. The Supreme Court dismissed Appellant’s appeal without addressing whether Appellant stated a cognizable claim for habeas relief, as it was apparent on the record that prior felony convictions, not juvenile-delinquency adjudications, were used in sentencing Appellant as a habitual offender. View "Davis v. Hobbs" on Justia Law

After a jury trial in 2008, Petitioner was found guilty of aggravated robbery and burglary. Petitioner’s motion for a new trial and petition for postconviction relief were denied. Petitioner subsequently filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court in order that he may proceed with a petition for writ of error coram nobis, claiming (1) his trial counsel was ineffective, (2) newly discovered evidence existed that questioned the credibility of the State’s witnesses, and (3) evidence was withheld by the prosecuting attorney’s office in violation of his constitutional rights, as recognized in Brady v. Maryland. The Supreme Court denied the writ, holding (1) Petitioner’s first two allegations were not a basis for the writ; and (2) Petitioner’s claims of a Brady violation were without merit. View "Burton v. State" on Justia Law

After a jury trial in 1985, Petitioner was found guilty of murder in the first degree and sentenced to life imprisonment. In 1987, the Supreme Court denied Petitioner’s petition to proceed in the trial court with a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Petitioner subsequently filed a second petition to reinvest jurisdiction in the trial court to consider a petition under the version of Rule 37.1 in effect when he became eligible to file a petition. The Supreme Court dismissed the petition and declared moot the motion Petitioner filed in relation to the petition, holding that the petition did not establish any good cause to permit a second petition. View "Alford v. State" on Justia Law

Arloe Designs, LLC proposed to build a building at an airport. Arkansas Capital Corporation (ACC) and National Bank of Arkansas (NBA) allegedly worked together to procure a loan for the building’s construction. After the NBA approved financing for the project, Arloe entered into a thirty-year lease for the new hangar. Later that month, Arloe learned that NBA would not close the loan without a bond as collateral, which Arloe did not give, and therefore, the loan was not closed. Arloe sued ACC and NBA, alleging breach of contract, violations of the Arkansas Deceptive Trades Practices Act, negligence, and promissory estoppel. The circuit court granted summary judgment to Defendants as to all but Arloe’s promissory estoppel claim, and limited damages for that claim to the money Arloe had spent in reliance on the claimed promise. At trial, a jury found Arloe had not proved that either defendant had made a promise to loan Arloe money. The Supreme Court affirmed, holding (1) Arloe’s claims that the circuit court erred in denying it recovery for lost profit damages and limiting its damages on its promissory-estoppel claim were moot; and (2) summary judgment was proper in regard to the remainder of Arloe’s claims. View "Arloe Designs LLC v. Ark. Capital Corp." on Justia Law

Appellant pleaded guilty to multiple counts of aggravated robbery and theft of property and was sentenced to an aggregate sentence of life imprisonment. Almost twenty years after the judgment had been entered, Appellant filed a pro se petition for writ of error coram nobis. The trial court denied the petition, concluding that the claims were either without merit or not within the purview of a coram-nobis proceeding and that Appellant did not act with due diligence in filing the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the coram-nobis petition. View "Wright v. State" on Justia Law

Appellant pleaded guilty to rape and was sentenced as a habitual offender to 180 months’ imprisonment. Appellant subsequently filed a petition for writ of habeas corpus, making several allegations. The circuit court denied the petition without a hearing, concluding that the allegations were conclusory in nature and failed to state a basis for a writ of habeas corpus to issue. The Supreme Court affirmed the circuit court’s order and denied Appellant’s motion to file a belated reply brief, holding that the circuit court did not err when it denied the petition, as Appellant did not establish a basis for a writ of habeas corpus to issue. View "Tolefree v. State" on Justia Law

After an automobile accident, Fran Biba sued Trevor Taylor and his employer, Rick Taylor, Inc. The district court awarded Biba damages and assigned Biba ten-percent fault, resulting in a judgment of $9,140. Taylor appealed by filing a certified docket sheet with the circuit court, but the docket sheet did include an entry for Biba’s “Answer to Counterclaim.” Biba filed a motion to dismiss the appeal due to Taylor’s failure to strictly comply with Ark. Dist. Ct. R. 9 because the certified docket sheet did not contain an entry for all the pleadings that had been filed. The circuit court granted Biba’s motion to dismiss, concluding that Rule 9(b) requires strict compliance, not substantial compliance, and that Taylor’s appeal had failed to comply with the rule. The Supreme Court reversed and remanded, holding that Taylor strictly complied with Rule 9(b), and therefore, the circuit court erred in granting Biba’s motion to dismiss. View "Taylor v. Biba" on Justia Law