Justia Arkansas Supreme Court Opinion Summaries

Appellant requested her medical records from a medical clinic. Pursuant to its contract with Appellant's medical care provider, Healthport, Inc., a private company that fulfills such requests for medical records, obtained and sold Appellant the copies of her requested medical records. Healthport collected sales tax on charges for services rendered in retrieving and copying the medical records. Appellant subsequently filed a class-action complaint against Healthport for violation of the Arkansas Deceptive Trade Practices Act (ADTPA), unjust enrichment, and a declaratory judgment that Healthport illegally collected the sales tax. Healthport impleaded the Arkansas Department of Finance and Administration (DF&A) by filing a counterclaim and a third-party complaint seeking declaratory judgment on whether the State's tax statutes require the collection of sales tax on labor and copy charges associated with the production of medical records. The circuit court granted Healthport's and DF&A's motions for summary judgment, finding that sales tax applied to the sale of copies of medical records and that this conclusion rendered Appellant's additional claims moot. The Supreme Court dismissed Appellant's appeal without prejudice for lack of a proper Ark. R. Civ. P. 54(b) certificate, as the circuit court's Rule 54(b) certificate failed to comply with Rule 54(b). View "Holbrook v. Healthport, Inc." on Justia Law

Johnny Washington and his son were traveling in their 1994 Ford Explorer when their vehicle was struck by a driver (Karah Williams) who had run a stop sign. The Explorer rolled over twice, fatally injuring Johnny. Paulette Washington, individually and as administratrix of Johnny's estate, filed a complaint against Ford Motor Company for negligence, strict liability, failure to warn, and breach of warranties. The jury returned a verdict finding that Ford and Williams, in equal measure, had been the proximate cause of Johnny's death. The jury awarded $4,652,125 in compensatory damages and $2.5 million in punitive damages. Ford appealed. The Supreme Court dismissed the appeal without prejudice for lack of jurisdiction, holding that the judgment was not final because it did not set forth a specific dollar amount owed by Ford. View "Ford Motor Co. v. Washington" on Justia Law

Appellant Crafton, Tull, Sparks & Associates (CTSA) appealed an order of the circuit court finding that CTSA's lien was second in priority to Appellee Metropolitan National Bank's lien on certain property. The circuit court filed an order titled "Final Judgment and Rule 65(b) certificate" stating that certain parties and actions remained unresolved. CTSA then brought this appeal. Although neither party raised the issue, the Supreme Court sua sponte raised the question of whether the order was final and subject to appeal. The Court dismissed the appeal without prejudice, holding that there was no final order or a sufficient Ark. R. Civ. P. 54(b) certificate, and therefore, the Court lacked jurisdiction to hear the appeal. View "Crafton Tull Sparks & Assocs. v. Ruskin Heights, LLC" on Justia Law

After a jury trial, Defendant was convicted of four counts of rape for which he received four consecutive terms of life imprisonment. The victim was less than fourteen years old when the rapes were committed. Defendant appealed, contending that the evidence was not sufficient to support three of the rape convictions. Because Defendant received a sentence of life in prison, the Supreme Court reviewed the record for all objections, motions, and requests that were decided adversely to Defendant. The Court found no prejudicial error, holding that substantial evidence supported Defendant's convictions for rape, as the testimony of a rape victim, standing alone, is sufficient to support a conviction if the testimony satisfies the statutory elements of rape. View "Christian v. State" on Justia Law

Defendant entered a conditional plea of guilty to driving without a driver's license. Defendant reserved the right to appeal the circuit court's denial of his motion to suppress evidence found in what he claimed was an illegal stop. Defendant was stopped for operating an unsafe motor vehicle when the arresting officer noticed a windshield crack on the vehicle Defendant was driving. Defendant appealed, arguing, among other things, that the traffic stop was based entirely on "profiling" and was thus illegal. The Supreme Court affirmed, holding (1) a windshield with a crack running from roof post to roof post across the driver's field of vision is the type of "safety defect" contemplated by Ark. Code Ann. 27-32-101(a)(2)(A), and therefore, the arresting officer's assessment that Defendant's cracked windshield constituted a safety defect was not a mistake of Arkansas law; and (2) the trial court did not err in crediting the arresting officer's testimony, and therefore, the Court had no reason to question the officer's credibility. View "Villanueva v. State" on Justia Law

Appellant was convicted of second-degree murder, endangering the welfare of a minor, and fleeing. Appellant received a total sentence of 1188 months' imprisonment. Appellant filed a notice of direct appeal, which remained pending in the court of appeals. Two days later, Appellant filed a petition for postconviction relief. The circuit court dismissed the petition, concluding that it lacked jurisdiction to consider the petition while Appellant's direct appeal of his conviction was pending. The Supreme Court dismissed Appellant's appeal of the denial of his petition for postconviction relief and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant's petition for postconviction relief was untimely, and therefore, the trial court and appellate court lacked jurisdiction to grant relief. View "Slocum v. State" on Justia Law

Appellant entered a plea of guilty in Howard County to breaking or entering and theft of property. While incarcerated, Appellant filed a pro se petition for writ of habeas corpus contending that Howard County did not have jurisdiction in this case because the information and warrants leading to Appellant's arrest were not signed by the circuit judge and stamped with the judge's seal and that the arrest was illegal. The circuit court denied the petition. The Supreme Court dismissed Appellant's appeal and declared the motions Appellant filed in relation to that appeal moot, holding that Appellant did not establish that a writ of habeas corpus was warranted in this case, as Appellant failed to assert allegations that were cognizable in a habeas proceeding. View "Roberson v. State" on Justia Law

Appellant issued a motorcycle insurance policy to Brian McCallum that contained accident and healthcare coverage. The policy included a provision for subrogation of payments made for any injury caused by a third party. After McCallum was involved in a collision with Margarita Saldivar, Appellant paid McCallum's medical expenses. Appellant then filed a complaint alleging Saldivar's negligence and seeking to receive subrogation benefits from Saldivar. The circuit court rejected Appellant's argument that it was entitled to subrogation benefits from Saldivar and granted summary judgment in Saldivar's favor. The Supreme Court reversed and remanded, holding (1) the circuit court erred in its interpretation of the relevant statutes; and (2) Appellant properly sought general "subrogation benefits from the third party,'" as permitted by Ark. Stat. Ann. 23-79-146. View "Progressive Halcyon Ins. v. Saldivar" on Justia Law

Plaintiff filed a complaint against Defendant in 1998, alleging that Defendant had breached a retail installment contract. After twelve months of no action of record, the circuit court dismissed the case without prejudice. Two months later, the parties appeared before the court to enter a consent judgment. A consent judgment was filed ordering that Plaintiff would recover $12,000 payable before August 18, 2002. The matter remained dormant for ten years until Plaintiff moved to revive the consent judgment. In response, Defendant filed several pleadings of its own. The circuit court denied Defendant's motions and allowed execution on the judgment. At issue before the Supreme Court was whether the circuit court had jurisdiction to enter a consent judgment in a case that had been dismissed. The Court reversed and dismissed, holding that the circuit court lost jurisdiction when it dismissed the case, and therefore, the court did not have jurisdiction to enter the consent judgment, making the consent judgment invalid. View "Crews v. Deere & Co." on Justia Law

In 2010, voters in the Fayetteville School District approved a 2.75 new-debt-service mills that would be a continuing debt service tax until the retirement of proposed bonds to be issued for the purpose of erecting and maintaining new and existing school facilities. The surplus revenues produced by debt service millage would be used for other school purposes. In 2011, certificates issued by the Washington County tax collector resulted in 1.45 mills of that 2.75-mill ad valorem increase being applied to the retirement of redevelopment-district bonds issued in 2005. The School District sought declaratory judgment and injunctive relief. The circuit court found that the assessor's certification was incorrect and that the tax collector improperly applied the 1.45 mills. The Supreme Court affirmed, holding (1) the present cause of action was not barred by res judicata; (2) Ark. Code Ann. 14-168-301(18)(B)(i) did not impair the bond-purchase contract and financing of the redevelopment bonds; and (3) the 2.75 expressly pledged the new millage to a bond in accordance with section 14-168-301(18)(B)(i). View "City of Fayetteville v. Fayetteville Sch. Dist. No. 1" on Justia Law