Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Petitioner was convicted of murder in the first degree and sentenced as a habitual offender to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner subsequently filed a verified pro se petition for postconviction relief, claiming that his ability to represent himself at trial acting pro se was compromised by the prosecution and his stand-by counsel and that his attorney on direct appeal was ineffective. The trial court denied the petition. No appeal was taken, and Petitioner sought leave to proceed with a belated appeal of the order. The Supreme Court denied the motion, holding (1) Petitioner's allegations regarding his first claim did not merit postconviction relief; and (2) Petitioner failed to show that he was prejudiced by his attorney's assistance on direct appeal. View "Walton v. State" on Justia Law

Appellant, an inmate in the Arkansas Department of Correction (ADC), filed a complaint against certain ADC authorities in their official capacities, seeking injunctive relief and damages against Appellees for their refusal to restore Appellant's Class I-B inmate status, which Appellant enjoyed while incarcerated in the county jail. Appellant also challenged Appellees' refusal to secure and provide to Appellant the privileges of Class I-B inmate status and their refusal to allow Appellant's participation in the prison's hobby-craft program. The circuit court dismissed the action with prejudice. The Supreme Court affirmed, holding that Appellant's complaint was barred by sovereign immunity and failed to state a claim upon which relief could be granted. View "Smith v. State" on Justia Law

After a jury trial, Appellant was convicted of aggravated robbery and theft of property and sentenced to 1080 months' imprisonment. The court of appeals affirmed. Appellant subsequently filed a pro se verified petition for postconviction relief, contending that he was not afforded effective assistance of counsel and that there were a number of errors in his trial. The circuit court denied the petition. Appellant appealed and filed a motion for extension of time to file his brief-in-chief. The Supreme Court dismissed Appellant's appeal and declared his motion moot, holding (1) Appellant did not provide any factual substantiation for his conclusory claims that counsel was ineffective; and (2) Appellant's claims of trial error did not state a basis for granting a postconviction relief petition. View "Nickelson v. State" on Justia Law

After Appellant submitted a petition for nomination for city director, the city clerk informed Appellant that her petition did not meet the statutory requirement of having fifty qualified electors. Appellant subsequently filed a petition for writ of mandamus and injunctive relief, requesting that the clerk be compelled to certify her as a candidate for the city director position and that an injunction issue to prevent the election board from taking any action that would affect her right to be considered as a candidate. The circuit court denied Appellant's petition and ordered the election commission to remove her name from the November 2012 election ballot. The Supreme Court dismissed Appellant's appeal as moot because the election had already been held and the Court was not persuaded that an exception should be made in this case. View "Lott v. Langley" on Justia Law

Plaintiff filed a petition against Defendants alleging a single cause of action for fraud. Plaintiff claimed that he purchased a house only after Defendants had misrepresented the location of the property's corners and lot lines, the location of the water well serving the property, and the availability of an easement to access the driveway leading to the house. Defendants filed a counterclaim for breach of contract relating to a waiver and release, alleging that, in the real-estate-sales contract, Plaintiff had agreed to forgo a survey and to hold them harmless for any boundary line or corner discrepancies that may exist and that in a closing document, Plaintiff agreed to release Defendants from any claims relating to the negotiation of the real-estate contract. The circuit court concluded that Defendants committed constructive fraud, awarding damages of $34,094 against Defendants and dismissing Defendants' counterclaim. The Supreme Court affirmed, holding that the circuit court did not err in (1) ruling that the waiver and release were vitiated by the constructive fraud; (2) ruling that Plaintiff's reliance on Defendants' marking of the boundaries was reasonable; (3) calculating damages; and (4) applying the burden of proof. View "Henry v. Mitchell" on Justia Law

After a trial, Appellant was convicted of unspecified offenses. Appellant subsequently filed a pro se petition for writ of error coram nobis, alleging numerous claims. The trial court denied the petition, finding Appellant's claims were not diligently filed, that alleged due process violations were not grounds for the writ, and that Appellant was competent at the time of the offense and competent to stand trial. The Supreme Court dismissed Appellant's appeal and declared his motion to have copies of his brief-in-chief duplicated at public expense moot, holding that, because two of the issues raised by Appellant were not cognizable in a proceeding for a writ of error coram nobis, and because Appellant failed to produce a sufficient record on which to consider his other claims, Appellant could not prevail on appeal. View "Greene v. State" on Justia Law

After a trial, Appellant was convicted of possession of a controlled substance, possession of drug paraphernalia, maintaining a drug premises, and simultaneous possession of drugs and firearms, for which he was sentenced to twenty-nine years' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief, alleging, among other claims, that he was denied his Sixth Amendment right to counsel of his choice. Appellant had requested a change of counsel on the eve of trial, and the circuit court denied the request despite the fact that Appellant had already obtained substitute counsel. The circuit court denied Appellant's petition for postconviction relief. The Supreme Court reversed, holding that the circuit court wrongly denied Appellant's motion to substitute new counsel because the court failed to consider Appellant's interests when deciding the motion. Remanded for a new trial. View "Arroyo v. State" on Justia Law

After a trial, Defendant was convicted of unidentified crimes. Defendant filed a petition for postconviction relief, contending that the circuit court erred in finding that his trial counsel did not render ineffective assistance by failing to object to the circuit court's change of venue and by failing to introduce the testimony of a witness at trial or offer transcribed testimony of the witness from a pretrial hearing to rebut an inference that Defendant had contemplated raping the victim. The Supreme Court declined to reach the merits of Defendant's argument because Defendant's brief did not comply with Ark. Sup. Ct. R. 4-2(a)(8) and he had failed to file a sufficient record for the Court's review. View "Thomas v. State" on Justia Law

Appellant filed a claim for benefits associated with an injury he received during his employment. The Arkansas Workers' Compensation Commissioned denied the claim based on a finding that Appellant tested positive for controlled substances after the injury and that he failed to rebut the statutory presumption that his injury was substantially occasioned by his drug use. Appellant appealed, arguing that the Commission's decision was not supported by substantial evidence and that the Commission lacked the authority to make credibility determinations contrary to those made by an ALJ. Currently before the Supreme Court was Defendant's motion to supplement the record with affidavits and depositions that Appellant attached to a brief he previously filed. The Supreme Court remanded to the Commission to settle the record to determine whether the documents were actually placed in the record. View "Prock v. Bull Shoals Boat Landing" on Justia Law

After Husband, who was a resident of Benton County, filed for divorce in Benton County, Wife, who filed for divorce later that same day in Washington County, moved to dismiss Husband's complaint, asserting that the proper venue was Washington County. The Benton County Circuit Court agreed with Wife and dismissed Husband's complaint. The Supreme Court reversed, holding that the trial court erred in dismissing Husband's complaint where (1) the doctrine of forum non conveniens, which Wife essentially invoked in her motion to dismiss, does not apply between counties in the state; and (2) the plain language of Ark. Code Ann. 9-12-303(a) lays venue where the complainant resides and section 9-12-303(c) grants the venue determination to the first Arkansas resident to file. View "Parker v. Parker" on Justia Law