Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Appellants Ricky Bruner and Melissa Workman were convicted of first-degree battery against their son. Bruner was sentenced to forty years in prison, and Workman received a sentence of life imprisonment. The Supreme Court affirmed Appellants' convictions and sentences, holding that the circuit court (1) did not abuse its discretion in excluding evidence of Appellants' mental condition; (2) did not err by failing to give an instruction on the lesser-included offense of third-degree battery; and (3) did not err in refusing to give a proffered jury instruction defining the phrase "manifesting extreme indifference to the value of human life." View "Bruner v. State" on Justia Law

Appellant Diane Ausman, the administrator of the Estate of Daniel Ausman, filed a complaint on August 24, 2009 against a geriatric center and doctor, alleging, among other claims, medical negligence and negligence. Shortly after the suit was filed, Appellant passed away. The attorneys representing Appellant did not learn of her death until May 2011. As a result, the attorneys filed a motion for a continuance of the trial, which was scheduled to begin on July 11, 2011. The parties disputed whether the one-year statute of limitations found in Ark. Code Ann. 16-62-108 was applicable where a special administrator of an estate dies during the pendency of litigation or whether the matter was simply governed by Ark. R. Civ. P. 25's requirement for substitution of parties. The circuit court dismissed the case with prejudice, finding that the Estate improperly failed to revive the action within one year from the date of Appellant's death. The Supreme Court affirmed, holding that the Estate's failure to move for substitution within one year from the time of Appellant's death prevented the revivor of the action. View "Ausman v. Hiram Shaddox Geriatric Ctr." on Justia Law

On November 15, 2011, Appellants filed a petition to modify a judgment entered on July 26, 2011 that granted two individuals a private road across property owned by Appellants. In Appellants' November petition they alleged that the order's failure to include the mandatory provisions required by Ark. Code Ann. 27-66-403 precluded it from being a final order from which an appeal could be taken. The county judge refused to act on Appellants' November petition, believing it was an untimely posttrial motion. On February 8, 2012, Appellants filed a petition seeking a writ of mandamus to compel the county judge to rule on the November petition to modify the July order. The circuit court refused to issue the writ. The Supreme Court affirmed, holding that the availability of direct appeal provided Appellants an adequate remedy at law and foreclosed their right to obtain an extraordinary writ. View "Veverka v. Gibson" on Justia Law

Petitioner was convicted of violating a protective order (judgment-and-commitment order). His probation of a prior offense (revocation order) was revoked because Petitioner had violated the order of protection. The court of appeals dismissed the appeals in both cases. The court of appeals dismissed the judgment-and-commitment order on the ground that the only notice of appeal that was filed pertained to the revocation order only. Before the Supreme Court was Petitioner's motion to proceed with a belated appeal in the judgment-and-commitment order. The Court treated the motion as a motion for rule on clerk and granted the motion, holding that Petitioner produced a record that demonstrated there was a timely notice of appeal filed with respect to the judgment and established that the appeal should go forward. View "Standridge v. State" on Justia Law

Appellant entered a conditional plea of guilty to one count of commercial burglary, reserving his right to appeal the denial of his motion to dismiss for a speedy-trial violation. On appeal, Appellant argued that the circuit court erred by denying his motion to dismiss because the State allegedly intentionally delayed the start of his twelve-month speedy-trial period by refusing to serve the arrest warrants issued for him when they knew he was incarcerated. The Supreme Court affirmed, holding that Appellant's argument had no merit, as the speedy-trial period begins to run on the date of arrest or service of summons and not when an arrest warrant has been issued, and therefore, the speedy-trial period had not yet expired at the time Appellant filed his motion to dismiss. Therefore, the circuit court properly denied the motion to dismiss. View "Robinson v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to the death penalty. After a mandatory review of Petitioner's conviction and sentence, the Supreme Court issued a mandate affirming the trial court's judgment. Petitioner subsequently petitioned the Supreme Court to recall its mandate and also filed a petition to reinvest the circuit court with jurisdiction to consider a petition for writ of error coram nobis. The Supreme Court denied both petitions, holding (1) Petitioner failed to demonstrate extraordinary circumstances resulting in a defect in the appellate process that warranted recall of the Court's mandatory-review mandate; (2) Petitioner failed to demonstrate that a recall of a the mandatory-review mandate was necessary based on Petitioner's allegation that there was an alleged breakdown in the postconviction process; and (3) Petitioner failed to proceed with diligence in pursuing coram nobis relief. View "Roberts v. State" on Justia Law

Petitioner was convicted of capital murder and sentenced to the death penalty for the murder of a twelve-year-old. Following his conviction, Petitioner filed a waiver of his right to appeal and postconviction review. Petitioner subsequently sought to rescind that waiver and asserted several bases on which the Supreme Court should reopen his postconviction proceedings and reinvest jurisdiction in the circuit court. The Supreme Court granted Petitioner's motion, holding that the Court previously failed to ensure that Petitioner was indeed competent to waive his rights to postconviction relief, and such extraordinary circumstances required the Court to reopen the proceedings. View "Roberts v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment without the possibility of parole. Appellant subsequently filed a petition for writ of habeas corpus, arguing that his life sentence was illegal because he was a minor when the crime was committed. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared Appellant's motions for appointment of counsel and extension of brief time moot, holding that Appellant failed to demonstrate that his sentence was illegal under Miller v. Alabama, and therefore, it was clear that Appellant could not prevail if his appeal were allowed to proceed. View "Murry v. Hobbs" on Justia Law

Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Forty-four months after the judgment of conviction had been entered against him, Appellant filed a petition under Act 1780 of 2001 to vacate or set aside the judgment. The circuit court denied the petition. Appellant appealed and requested an extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion for extension of time moot, holding that the decision to deny the requested relief was not clearly erroneous, as (1) Appellant failed to rebut the presumption against timeliness on his request for DNA testing; and (2) none of the other claims that Appellant raised were grounds for relief under Act 1780. View "Foster v. State" on Justia Law

After a jury trial, Defendant was convicted of capital felony murder and aggravated robbery, with a firearm enhancement on each count. Defendant was sentenced to life imprisonment without the possibility of parole for the murder. The Supreme Court affirmed, holding (1) the evidence supported a conclusion that Defendants death occurred during the commission of an aggravated robbery under circumstances manifesting extreme indifference to the value of human life, and thus Defendant's convictions were supported by sufficient evidence; and (2) Defendant failed to preserve for appeal his final two arguments, including his claim that the circuit court erred in prohibiting defense counsel from informing the jury that Defendant would be automatically sentenced to life without parole if convicted of capital felony murder. View "Bradley v. State" on Justia Law