Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of capital murder and aggravated robbery and sentenced as a habitual offender to an aggregate term of life imprisonment without parole. Appellant subsequently field a pro se petition for writ of habeas corpus, seeking scientific testing of a gun discovered inside the apartment shared by the victim and a witness to the murder and of shell casings found outside the apartment. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and mooted the motions related to the appeal, holding (1) because Appellant did not show the testing could satisfy Ark. Code Ann. 16-112-202, the circuit court did not err in denying relief; and (2) dismissal of the petition was proper because it was not timely filed. View "Gardner v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of rape and one count of sexual assault in the second degree. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial attorneys had rendered effective assistance. The trial court dismissed the petition. The Supreme Court affirmed the dismissal and mooted the motions related to Appellant's appeal, holding (1) the trial court did not err in finding that counsel did not provide ineffective assistance; and (2) the trial court did not err in failing to hold a hearing on Appellant's postconviction relief petition. View "Garcia v. State" on Justia Law

On July 11, 2012, Appellees filed a complaint for declaratory judgment and mandamus in the circuit court requesting that the court enter an order (1) declaring that the filing period for independent candidates for municipal offices for the City of Helena-West Helena starts July 27, 2012, and (2) mandating that city officials notify election officials of the proper filing date. The circuit court granted the complaint. Appellants filed a motion to intervene on August 6, 2012 and August 8, 2012. The circuit court denied the motions in orders entered October 12, 2012 and October 18, 2012, concluding that both motions were untimely. The Supreme Court did not reach the merits of Appellants' arguments on appeal because (1) the filing period at issue concerned the now-past November 6, 2012 election; and (2) both Appellants won their respective races in the election. View "Etherly v. Newsome" on Justia Law

In this school-funding dispute, a school district (District) filed an action on its own behalf and on behalf of its taxpayers to enjoin state actions in violation of state law and the Arkansas Constitution. The District alleged two claims against Appellees. The District then voluntarily nonsuited the special-and-local legislation claim so it could immediately appeal the adequacy claim in the "Beebe" case. The District brought the special-and-local-legislation claim as a separate case in the "Kimbrell" case. The Supreme Court dismissed the appeal of the Beebe case for a lack of finality. The circuit court subsequently consolidated the Beebe case and the Kimbrell case. After the circuit court decided the cases, the District appealed. The Supreme Court affirmed in part, reversed and remanded in part, and mooted in part, holding (1) the circuit court abused its discretion in ruling that some of the District's claims in the Beebe case were barred by res judicata but did not err in dismissing the District's other claims as barred by res judicata; (2) the circuit court did not err in striking the District's amended and supplemental complaint; and (3) the District's claims in the Kimbrell case were moot. View "Deer-Mt. Judea Sch. Dist. v. Kimbrell" on Justia Law

Plaintiffs filed suit against Defendant for breach of a real estate contract after Defendant was unable to acquire financing to purchase a home owned by Plaintiffs. Defendant filed a third-party complaint against his real estate agent and the agent's employer. A jury returned a verdict in the Clines' favor on the breach of contract claim and in favor of Defendant on the third-party negligence claim. The Supreme Court reversed the award to Plaintiffs, holding that there was no contract between the parties. On remand, the circuit court dismissed the complaint and third-party complaint. Thereafter, Defendant filed a motion for attorney's fees and costs based on a provision in the real estate contract. The trial court awarded Defendant fees and costs but at an amount significantly less than the amount Defendant had requested. The Supreme Court affirmed, holding (1) the circuit court's finding that Defendant was not entitled to recover fees and costs under the contract was consistent with the Court's holding in Carter I that there was no contract; and (2) the circuit court did not err in finding that Appellant was not entitled to recover fees and costs related to his third-party claim and those fees and costs associated with his attorney. View "Carter v. Cline" on Justia Law

Petitioner filed a pro se petition for writ of error coram nobis in his criminal case, which was denied. Petitioner subsequently filed a motion for belated appeal in order to challenge the order denying his motion. Plaintiff, however, sought to appeal without a certified record or, in the alternative, sought an order directing the circuit clerk to provide the certified record necessary to file the motion for belated appeal. The Supreme Court denied the motion because Petitioner failed to meet his burden of providing a certified record with a motion for belated appeal sufficient to establish the Supreme Court's jurisdiction and sufficient to allow the Court to rule on the merits of his motion. View "Bannister v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder, committing a terroristic act, and using a firearm during the commission of a felony. Appellant was sentenced to life imprisonment plus a term of ten years. Appellant appealed, arguing that the circuit court erred in excluding Ark. R. Evid. 404(b) testimony about the alleged bad acts by the State's primary eyewitness. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in excluding the evidence because Appellant failed to show that the testimony regarding the eyewitness's bad acts was relevant to any material issue in this case. View "Allen v. State" on Justia Law

After a jury trial, Appellant was convicted of rape and sentenced to 720 months' imprisonment. Appellant subsequently filed a pro se petition for postconviction relief under Ark. R. Crim. P. 37.1, raising several grounds for relief. The trial court denied the petition. Appellant appealed, arguing that his counsel provided ineffective assistance. The Supreme Court affirmed, holding (1) because Appellant did not raise his ineffective assistance of counsel claim in the postconviction petition, the argument would not be addressed by the Court on appeal; and (2) to the extent Appellant argued that the evidence was insufficient to sustain the judgment, Rule 37.1 does not provide a means to attack the weight of the evidence to support the conviction. View "Williams v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree. The jury declared that Appellant's sentence of 480 months' imprisonment should be enhanced by an additional term of 180 months' imprisonment for use of a firearm in the commission of the felony. The sentences were to be served consecutively. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging, among other claims, that the trial court erred when it accepted the jury's recommendation and ordered the sentences to be served consecutively. The circuit court denied the petition. The Supreme Court affirmed, holding that because Appellant's claims did not demonstrate the facial invalidity of the judgment and failed to demonstrate a lack of the trial court's jurisdiction, Appellant did not establish a basis for the writ to issue. View "Tate v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of rape and sentenced to two consecutive life sentences. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, alleging a number of grounds for relief. The circuit court dismissed the petition without a hearing. Appellant appealed, stating that he was entitled to habeas relief based on, inter alia, violations of due process, prosecutorial misconduct, and ineffective assistance of counsel. The Supreme Court affirmed, holding (1) the circuit court did not err by not conducting a hearing, as Appellant failed to demonstrate probable cause for the issuance of the writ; (2) the circuit court did not err by not making extensive written findings to support its decision; (3) several of Appellant's arguments on appeal were barred by the law-of-the-case doctrine; and (4) Appellant's reviewable claims were without merit. View "Strong v. Hobbs" on Justia Law