Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of multiple drug-related offenses. The court of appeals affirmed. Defendant subsequently filed a petition for postconviction relief, alleging that his trial counsel was ineffective for failing to impeach one of the state's witnesses, failing to object to comments made by the State in closing arguments, and failing to challenge the jury-selection process, among other reasons. The circuit court denied Appellant's petition without a hearing. The Supreme Court affirmed the denial of postconviction relief on all points, holding that the circuit court did not commit prejudicial error in denying postconviction relief. View "Bond v. State" on Justia Law

In 2005, Appellant pled guilty to failure to register as a convicted sex offender by virtue of a 1994 conviction for rape. In 2006, he pled guilty to the same charge. In 2008, Appellant's rape conviction was vacated, and Appellant was no longer required to register as a sex offender. Appellant subsequently filed a series of petitions for postconviction relief to vacate the judgments in 2005 and 2006, claiming that his convictions for failing to register as a sex offender were invalid because the rape conviction had been set aside. The petitions were unsuccessful. In 2013, Appellant filed another challenge to the two convictions, which was denied. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding that Appellant's claims were untimely. View "Wright v. State" on Justia Law

The Hernandezes (Hernandez) entered into a real-estate contract to buy 100 acres of land in Van Buren County from the Humphries (Humphries). The sales contract included the mineral rights to the property. However, Humphries subsequently leased the oil-and-gas rights to New Century, which assigned the rights to SEECO. Humphries then sold the oil-and-gas rights to Paraclifta and Claughton. Therafter, Hernandez entered into a contract for sale of the property to the Walls (Walls). Hernandez and Walls (Appellants) filed suit against New Century, SEECO, Paraclifta, and Claughton (Appellees), alleging that Appellees were not innocent purchasers the oil-and-gas rights and seeking cancellation of the lease issued to New Century and the assignment to SEECO, as well as the deed conveying the rights to Paraclifta and Claughton. The circuit court granted Appellees' motions for summary judgment and Appellees' requested attorney fees. The Supreme Court reversed and remanded, holding (1) a question of fact remanded as to whether Hernandez was in exclusive possession of the property, thus imputing notice of Hernandez's interest in the property; and (2) the circuit court abused its discretion in awarding attorneys' fees. View "Walls v. Humphries" on Justia Law

Appellants filed a class action complaint against TV Guide Online Holdings, claiming that, upon accessing TV Guide's website, TV Guide downloaded a Flash cookie onto their computers without their knowledge or consent. Appellants alleged that they were residents of Washington County and that a substantial part of the events giving rise to their claims occurred in Washington County. TV Guide filed a motion to dismiss on the basis that Appellants had not pleaded facts sufficient to show that venue was proper in Washington County. The circuit court granted the motion, concluding that Appellants had not pleaded sufficient facts to avoid jurisdiction and venue in Los Angeles, California because, by using TV Guide's website, Appellants had consented to venue in Los Angeles. The Supreme Court reversed and remanded, holding (1) subject-matter jurisdiction cannot be created or waived by agreement between the parties; (2) TV Guide did not meet its burden of showing that an enforceable agreement existed between it and Appellants relating to the proper venue in which to bring claims; and (3) TV Guide failed to establish that venue was improper in Washington County. View "Roller v. TV Guide Online Holdings, LLC" on Justia Law

After a jury trial, Petitioner was convicted of rape and sentenced as a habitual offender to life imprisonment. Petitioner subsequently filed a pro se petition seeking to have jurisdiction reinvested in the trial court to consider a petition for writ of error coram nobis. After the petition was denied, Petitioner filed another pro se petition seeking leave to have jurisdiction reinvested in the trial court to consider a coram-nobis petition. The Supreme Court dismissed the petition, holding that Petitioner's successive application for coram-nobis relief was an abuse of the writ in that Petitioner alleged no facts sufficient to distinguish his claim in the instant petition from the claim in the first. View "Rodgers v. State" on Justia Law

Employee was employer at Employer's aluminum-processing plant from 1957 to 1989. In 2009, Employee filed an occupational-disease claim for benefits with the Arkansas Workers' Compensation Commission, alleging that he suffered from cancer caused by his exposure to asbestos while working for Employer. A law judge found Employee's complaint was time barred. Rather than appeal the decision to the full Commission, Employee filed suit against Employer in circuit court. Employer filed a motion to dismiss based on the exclusive remedy afforded by the Workers' Compensation Act. The circuit court denied the motion, concluding that, where a plaintiff's disease manifests after the statute of limitations has expired, a circuit court has authority to exercise jurisdiction over the plaintiff's claims. The Supreme Court granted Employer's requested writ of prohibition, holding that the Commission had exclusive jurisdiction to decide the issue in the first instance, and because Employee's claim was not submitted to the Commission, the circuit court lacked jurisdiction to decide the case. View "Reynolds Metal Co. v. Circuit Court" on Justia Law

After A.S.'s sister suffered a nonaccidental death, the circuit court found A.S. dependent-neglected. A termination hearing was subsequently held, after which the circuit court found termination of Mother's parental rights was in A.S.'s best interest and terminated Mother's parental rights. Mother appealed, arguing that because a jury convicted her boyfriend for the death of C.S., her parental rights as to A.S. were wrongly terminated. The Supreme Court remanded the case and ordered that a supplemental record be filed, holding that because none of Mother's testimony and other evidence presented at the adjudication hearing was included in the record, the record must be supplemented with Mother's testimony and anything else that was relevant to the termination hearing and the final order of the circuit court. View "Payne v. Dep't of Human Servs." on Justia Law

Defendant was fined in the district court for driving sixteen miles over the speed limit. On appeal, Defendant was convicted of speeding in excess of fifteen miles per hour over the speed limit. The court of appeals reversed and dismissed Defendant's conviction. Defendant subsequently filed a motion for award of costs on appeal under Ark. R. Sup. Ct. 6-7. The Supreme Court accepted certification from the court of appeals to determine whether the State may be liable for costs under Rule 6-7. The Supreme Court denied the motion for costs on appeal, holding that Defendant's claim against the State was barred by the doctrine of sovereign immunity. View "Kiesling-Daugherty v. State" on Justia Law

After a jury trial, Appellant was convicted of murder in the first degree and sentenced to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, alleging that he was not afforded effective assistance of counsel at trial. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant's allegation that his trial counsel was ineffective for failing to call a witness during the penalty phase of his trial was conclusory and thus without merit; and (2) the trial court did not err in finding Defendant's claim that his attorney should have secured a change of venue was conclusory in nature and not supported by facts. View "James v. State" on Justia Law

After a jury trial, Defendant was found guilty of murder in the first degree and sentenced to life imprisonment. Defendant subsequently filed a petition for postconviction relief, which was denied. Thereafter, Defendant filed a successive petition to correct an illegal sentence, arguing that his sentence was illegal because the State was allowed to amend the information to charge him with first-degree murder by premeditation and deliberation. The trial court denied the petition. The Supreme Court affirmed, holding that the trial court did not err in denying Defendant's petition, as the sentenced imposed was within the sentencing range for the offense of first-degree murder. View "Hill v. State" on Justia Law