Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of several felonies and sentenced to life imprisonment as a habitual offender. The Supreme Court affirmed on appeal, holding (1) the circuit court did not err in denying Defendant's motion to dismiss on speedy-trial grounds, as there was no speedy-trial violation in this case; and (2) the two fifteen-year sentences imposed on Defendant for having used a firearm to commit aggravated robbery and theft of property were not illegal, as Defendant failed to demonstrate that the Court's holding in Williams v. State, in which the Court addressed the issue, was patently wrong or manifestly unjust. View "Smith v. State" on Justia Law

After a jury trial, Appellant was convicted of capital murder and sentenced to life imprisonment without parole. Appellant appealed, arguing (1) the circuit court should have granted his motion for acquittal because at the time of the charged conduct, he lacked capacity as a result of mental disease or defect to conform his conduct to the requirements of the law or to appreciate the criminality of his conduct; and (2) the circuit court erred in denying his motion for a mistrial after the jury announced that it was deadlocked. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in denying Appellant's motion for acquittal; and (2) Appellant's second argument was not preserved for appellate review. View "Russell v. State" on Justia Law

Randy Russell filed for divorce from Andrea Russell in 2006, alleging general indignities. Andrea counterclaimed, alleging the same grounds. After a trial, the circuit court issued a divorce decree that ordered Randy to buy at their inferential value corporate shares from Andrea instead of simply distributing existing marital property. Randy appealed this portion of the order. The circuit court also found that the business, National Recovery Specialists (NRS), had a fair-market value independent of the personal goodwill of Randy's stepfather in its valuation of the NRS shares. The Supreme Court affirmed, holding (1) the circuit court did not err in ordering Randy to pay alimony as a complementary device to offset the unequal distribution of marital property; and (2) Randy's contention that Andrea presented no competent evidence that NRS had a fair-market value independent of Randy's stepfather's personal goodwill was not supported by the record. View "Russell v. Russell" on Justia Law

Appellant pled guilty to multiple felony offenses and was sentenced to an aggregate term of 420 months' imprisonment. Appellant subsequently filed in the Mississippi County trial court a pro se petition for writ of habeas corpus and a pro se motion to rescind the plea agreement he entered when he pled guilty. Appellant was incarcerated in Lee County when he filed the habeas corpus petition. The trial court denied both pleadings. The Supreme Court affirmed, holding that because Appellant was not incarcerated within the jurisdiction of the trial court in Mississippi County when he filed the petition, the court did not have personal jurisdiction to issue and make returnable a writ. View "Rivers v. State" on Justia Law

Appellant pled guilty to capital murder and was sentenced to life imprisonment without parole. Appellant later filed a pro se petition for writ of habeas corpus, arguing that he was insane or mentally incompetent at the time he entered his plea and that the trial court was deprived of jurisdiction to try an insane or mentally incompetent person. The circuit court declined to issue the writ. The Supreme Court affirmed, holding that because Appellant's petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court's jurisdiction, Appellant failed to establish a basis for a writ of habeas corpus to issue. View "Matthews v. Hobbs" on Justia Law

Plaintiff obtained a last will and testament from LegalZoom.com. Before receiving the requested document, Plaintiff agreed to LegalZoom.com's terms of service, which included an arbitration provision. The agreement also provided that the Federal Arbitration Act (FAA) governed the interpretation and enforcement of the agreement's provisions. Plaintiff later filed a class-action lawsuit, alleging that LegalZoom.com engaged in the unauthorized practice of law, among other claims. LegalZoom.com filed a motion to compel arbitration. The trial court denied the motion based upon the allegations concerning the unauthorized practice of law. The Supreme Court reversed, holding (1) the circuit court erred because Arkansas law does not prohibit the enforcement of arbitration agreements requiring resolution through arbitration of private claims when a dispute concerns allegations of the unauthorized practice of law; and (2) any rule prohibiting arbitration of unauthorized practice-of-law claims were preempted by the FAA in this case. View "Legalzoom.com, Inc. v. McIllwain" on Justia Law

Appellant was convicted of first-degree murder in a shooting death and sentenced to 480 months' imprisonment. The conviction was affirmed on appeal. Appellant subsequently filed a petition for postconviction relief, which the trial court denied. Appellant appealed, contending, among other things, that trial counsel was ineffective for failing to have a gun tested that was discovered in another person's possession months after the murder. The Supreme Court reversed, holding that the trial court clearly erred in finding that counsel's decision not to test the gun was reasonable, and the additional evidence may have changed the outcome of the trial. Remanded. View "Houston v. State" on Justia Law

After a trial, Appellant was conviction of first-degree murder and sentenced as a habitual offender to 720 months' imprisonment. No appeal was taken from the judgment. Appellant subsequently filed a writ of error coram nobis, raising a number of claims. The trial court denied the writ. Appellant appealed, raising as his sole point on appeal an allegation of error concerning a claim of withheld evidence. The Supreme Court affirmed, holding that the trial court did not err in denying coram nobis relief where Appellant's pleading failed to demonstrate that the evidence he contended was withheld was sufficient to support issuance of the writ. View "Hill v. State" on Justia Law

Appellant was in the business of extending high-risk loans to customers with poor credit ratings and operated primarily in Louisiana. Appellees, who resided in Arkansas, obtained four loans from Appellant at its location in Louisiana. After Appellees failed to make payments on the loans, Appellant filed in an Arkansas circuit court a notice of default and intention to sell Appellees' home. Appellees asserted the defenses of usury, unconscionability, esoppel, unclean hands, predatory lending practices, and a violation of the Arkansas Deceptive Trade Practices Act. The circuit court found that the loans constituted predatory lending by a foreign corporation not authorized to do business in Arkansas and that the contract between the parties was unconscionable and could not be given full faith and credit. The Supreme Court affirmed, holding (1) the circuit court's findings of unconscionability and predatory lending practices were not clearly erroneous; and (2) court did not err in refusing to enforce the mortgage, as to do so would contravene the public policy of the State of Arkansas. View "Gulfco of La. Inc. v. Brantley" on Justia Law

Appellant pleaded guilty to possession of a controlled substance and the manufacture, delivery, or possession of marijuana and was sentenced to 120 months' incarceration. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of counsel and due-process and equal-protection violations. The trial court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant could not prevail on his claim of ineffective assistance of counsel because he failed to demonstrate that the argument he contended counsel should have made had merit; and (2) to the extent that Appellant's independent constitutional claims may have been cognizable in a postconviction proceeding, the claims failed because the basis of Appellant's claims was without merit. View "Dotson v. State" on Justia Law