Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Arkansas Supreme Court
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After a jury trial, Appellant was found guilty of capital murder and sentenced to life without parole. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, contending that he was not afforded effective assistance of counsel. The trial court denied the petition. Appellant appealed and sought by pro se motion an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that it was clear from the record that Appellant could not prevail on appeal if the appeal were permitted to go forward. View "Wedgeworth v. State" on Justia Law

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After Mother gave birth to Child, Grandmother filed a petition to establish grandparent visitation with Child, which was granted. Couple subsequently filed a petition seeking to adopt Child, and the circuit judge entered a decree for the adoption of Child by Couple. Mother then filed a motion to terminate Grandmother's visitation rights with Child, arguing that Grandmother's visitations with Child were derived from her relationship as a biological grandmother and that the adoption severed this relationship. Grandmother also filed a motion for contempt in the visitation action, alleging that Mother had denied visitation on two occasions. Ultimately, the judge held Mother in contempt, denied Mother's motion to terminate visitation, and found that the adoption decree did not specifically terminate Grandmother's visitation rights. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) Child's adoption terminated Grandmother's visitation rights in Child, and accordingly, the circuit court erred by continuing to recognize Grandmother's visitation rights following the adoption; (2) the circuit court's finding of contempt was not clearly against the preponderance of the evidence; and (3) the circuit court abused its discretion in the amount of fees awarded to Grandmother. View "Scudder v. Ramsey" on Justia Law

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Petitioner was charged with capital murder and permitting the abuse of a minor by felony information on March 20, 2012. Petitioner pled not guilty to the charges, and the court set the case for jury trial on October 22, 2012. Citing trouble obtaining military records for mitigation purposes, Petitioner filed a motion for continuance. The court denied the motion without prejudice. On September 27, 2012, Petitioner filed a renewal of his motion for continuance, citing various objections. After a hearing, the court found that Defendant had failed to make the requisite factual showing and denied the motion. Thereafter, Petitioner filed a petition for writ of certiorari, maintaining that because of the special circumstances of this case - a complex death penalty case slated for trial merely six months after Petitioner was afforded the benefit of counsel - the Court should grant relief. The Supreme Court denied the writ because Petitioner had another adequate remedy at law - an appeal. View "Pedraza v. Circuit Court" on Justia Law

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Petitioner filed a pro se petition for writ of mandamus in the Supreme Court, alleging that the circuit court judge failed to act in a timely manner on a petition for postconviction relief Petitioner filed in 2009. While the judge was unable to determine the exact cause of the delay, the Supreme Court concluded that the delay was an anomaly resulting from clerical error rather than the consequence of a failure to have appropriate procedures in place. The Court then declared the petition for mandamus moot because the underlying petition was acted on by the circuit court. View "Paige v. Circuit Court (Reynolds)" on Justia Law

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Petitioner filed a complaint against his employer (Employer), alleging that he was terminated in retaliation for asserting his rights under the Arkansas workers' compensation statutes. After the case was removed to federal court, Employer filed a motion to dismiss, asserting that the claim for retaliation had been abolished under Ark. Code Ann. 11-9-107, and therefore, Petitioner failed to state a claim. Petitioner argued that he was seeking relief allowed under Ark. Code Ann. 16-118-107, the crime victims' civil-liability statute for felonious conduct. The Supreme Court accepted certification to answer a question of law and held that, by enacting section 16-118-107 under the Workers' Compensation Act, the Arkansas General Assembly did not intend to revive the individual cause of action for common-law remedies for retaliation under Arkansas' workers' compensation law that it expressly annulled at section 11-9-107, and therefore, the exclusive remedy provision of the Act precluded recovery under section 16-118-107. View "Lambert v. LQ Mgmt. LLC" on Justia Law

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Defendant was convicted and sentenced in the underlying criminal case. Defendant subsequently filed a pro se motion seeking leave to file a pro se petition for rehearing, challenging the admissibility of certain evidence and the sufficiency of the evidence to sustain the judgment, and arguing that his trial counsel provided ineffective assistance. The Supreme Court denied the motion, as Petitioner was represented by counsel on appeal who did not elect to file a petition for rehearing, and Petitioner's claim of ineffective assistance of counsel was not properly raised in a belated petition for rehearing. View "Fields v. State" on Justia Law

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Appellant was convicted of several counts of breaking or entering and theft of property and sentenced to 480 months' incarceration. After the judgment was affirmed on appeal, Appellant filed a pro se petition for postconviction relief, raising a number of claims, including ineffective assistance of counsel and due-process violations. The trial court denied the petition, finding that Appellant had failed to present proof to support each of his claims. Appellant appealed and then filed a motion for an extension of time in which to file his brief and five other motions, all of which indicated an intention to supplement the record. The Supreme Court (1) granted in part, denied in part, and declared moot in part Appellant's motions to supplement; (2) declared moot Appellant's motion for extension of time; and (3) dismissed the appeal, holding that the trial court's findings in its order denying postconviction relief were not clearly erroneous, and Appellant could not prevail on appeal. View "Davis v. State" on Justia Law

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Appellant submitted a proposal to the City of Pine Bluff Planning Commission requesting a Use Permitted on Review permit to utilize certain premises in Pine Bluff as a foster-care facility for displaced children. The Planning Commission and City Council denied Appellant's request. On appeal, the circuit court granted summary judgment for the City, concluding that, although Pine Bluff City Ordinance 29-37 conferred standing on Appellant to bring the action, the ordinance was in conflict with Ark. R. Civ. P. 17, which requires that an action be brought by the real party in interest, and Rule 17 overrode the ordinance. Consequently, the circuit court ruled that, because Appellant was not the real party in interest, she lacked standing to bring suit. The Supreme Court affirmed, holding that because the record did not contain the ordinance, the record was inadequate for review. View "Coleman v. City of Pine Bluff" on Justia Law

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Appellant filed in the circuit court a pro se petition for postconviction relief. Appellant indicated in the heading to the petition that the petition encompassed six cases, and Appellant further indicated that he had entered pleas of guilty to felony offenses in the six cases. The trial court denied the petition. Appellant lodged an appeal and filed a motion for an extension of time to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the record on appeal was clearly deficient because it contained only one judgment, and therefore, the record was not sufficient to determine if the issues for reversal were well founded or if the petition was timely filed as to every judgment. View "Townsend v. State" on Justia Law

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After a jury trial, Defendant was convicted of the first-degree murder of Michael Fox, who suffered three stab wounds. Defendant was sentenced to life in prison. The Supreme Court affirmed the conviction and sentence, holding that the circuit court (1) did not err in denying Defendant's directed-verdict motion, as substantial evidence supported the verdict; (2) did not err in denying Defendant's motion to suppress his statement to a police officer; (3) did not abuse its discretion in denying Defendant's motion for mistrial; (4) did not abuse its discretion in denying Defendant's motions to exclude prior bad acts involving Defendant's use of a knife; and (5) did not abuse its discretion in failing to exclude a plaster cast of the knife impression found in a seized knife box. View "Stevenson v. State" on Justia Law