Justia Arkansas Supreme Court Opinion Summaries

In 1997, Petitioner was convicted of multiple felony offenses. An aggregate term of life imprisonment was imposed. Petitioner later attempted to pursue postconviction relief, but his efforts were dismissed. In 2012, Petitioner filed a pleading entitled "motion to vacate a void judgment" in which he alleged the trial court had lacked subject-matter jurisdiction to convict him. Petitioner subsequently filed a petition for writ of mandamus asking that the Supreme Court direct the circuit court to enter an order disposing of Petitioner's 2012 motion. The State responded that the circuit court had in fact acted upon Appellant's petition and appended to its response a copy of the circuit court's order denying the petition. The Supreme Court therefore declared the petition for writ of mandamus moot. View "Watts v. Griffen" on Justia Law

Upon stopping Defendant and boarding his boat to perform a safety check, an enforcement division officer of the Arkansas Game and Fish Commission concluded that Defendant was under the influence of alcohol. Defendant entered a no-contest plea to boating while intoxicated. Defendant appealed, alleging that the Game and Fish officers had no authority to stop and arrest him and that there was a lack of probable cause for the stop. The circuit court reversed, holding that the stop of Defendant's vehicle was unreasonable under the circumstances and violated Defendant's Fourth Amendment rights. The Supreme Court affirmed, holding that the practice of safety-check stops by law-enforcement officers in this case violated the Fourth Amendment. View "State v. Allen" on Justia Law

Appellees Edgar and Clara Shelton filed a complaint against St. Vincent Infirmary Medical Center, Catholic Health Initiatives (collectively, Appellants) and Golden Living Center, alleging negligence, medical malpractice, and violations of the Arkansas Long Term Care Resident's Rights Statute for Edgar's treatment while he was a patient at the facilities. Golden Living was dismissed from the suit after a settlement. Appellants subsequently filed a cross-claim and third-party complaint against Golden Living. The circuit court struck Appellants' cross-claim and third-party complaint, finding that Appellants did not have a claim or cause of action against Golden Living. The Supreme Court affirmed, holding (1) the circuit court did not abuse its discretion in striking Appellants' third-party complaint; and (2) the dismissal of Appellants' third-party complaint did not operate to prevent Appellants from presenting to the jury potential evidence of Golden Living's responsibility for a portion of Edgar's injuries. View "St. Vincent Infirmary Med. Ctr. v. Shelton" on Justia Law

After a jury trial, Petitioner was found guilty of attempted first-degree murder and first-degree battery. Petitioner subsequently filed a timely pro se petition for postconviction relief, which the trial court denied. Petitioner did not timely file a notice of appeal from the order and sought leave to proceed with a belated appeal. The Supreme Court granted the motion, holding that Petitioner established good cause for his failure to file a timely notice of appeal, as nothing in the record suggested that Petition was properly notified that the order denying his postconviction relief petition had been entered, and because the record was silent, the Court must assume that Petitioner was not properly notified. View "Robinson v. State" on Justia Law

A disciplinary action was imposed upon Appellant, an inmate of the Arkansas Department of Correction (ADC). Appellant filed a petition for judicial review and declaratory judgment seeking to challenge the dismissal of his grievance concerning the disciplinary action, the application of an administrative directive by prison officials, and policies he asserted were in violation of contractual obligations of the ADC concerning his conduct in regard to hobby crafts while incarcerated. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court correctly determined that Appellant's petition did not set forth facts to show deprivation of a liberty interest and, as a result, Appellant failed to sustain a claim under the Arkansas Administrative Review Act to support a judicial review of the ADC's decision. View "Renfro v. Smith" on Justia Law

Appellant was charged with capital murder and subsequently entered a negotiated plea of guilty to first-degree murder and received a sentence of 420 months' imprisonment. Appellant filed a timely pro se petition for postconviction relief, setting forth three claims for relief, each asserting that his trial counsel was ineffective. The trial court denied the petition without a hearing. The Supreme Court affirmed the order, holding that it was clear from the face of the petition that the allegations in the petition were without merit, as Appellant failed to allege any facts to support a demonstration of prejudice concerning his claims. View "Pennington v. State" on Justia Law

After a jury trial, Appellant was found guilty of rape and sexual abuse and sentenced to an aggregate term of life imprisonment. The Supreme Court affirmed. More than seventeen years after he was convicted of the offenses, Appellant filed a pro se motion for a new trial, contending, among other things, that the evidence at his trial was insufficient to sustain the verdict. The trial court denied the motion. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding (1) the motion for a new trial raised issues that could have been settled at trial or in a timely petition for postconviction relief; and (2) as such, Appellant could not prevail on appeal. View "Mills v. State" on Justia Law

Appellant was convicted of capital murder and aggravated robbery and sentenced to death and life imprisonment. The circuit court denied Appellant's subsequent motion for postconviction relief that alleged ineffective assistance of counsel. Appellant appealed and filed a motion for reconsideration. The circuit court denied the motion without an evidentiary hearing, concluding that Appellant was not entitled to relief on his claim that counsel was ineffective for failing to call a psychologist to testify as to Defendant's chronic substance abuse. The Supreme Court reversed and remanded for an evidentiary hearing, holding that the circuit court erred in failing to hold an evidentiary hearing, as the record did not conclusively show that Petitioner was not entitled to relief. View "Lacy v. State" on Justia Law

Petitioner was found guilty of sexual assault in the second degree and rape and was sentenced to an aggregate term of 720 months' imprisonment. Twenty-one months after the court of appeals issued a mandate affirming the convictions and sentences, Petitioner filed a pro se request for relief that the trial court treated as a petition for postconviction relief. The court dismissed the petition as untimely. Before the Supreme Court was Petitioner's motion for rule on clerk, seeking leave to lodge the record belatedly and proceed with an appeal. The Court denied the motion, holding that because the petition before the trial court was not timely filed, the trial court had no jurisdiction to grant the relief sought, and therefore, the appellate court also lacked jurisdiction. View "Holliday v. State" on Justia Law

Petitioner, proceeding pro se, sought a writ of mandamus and other relief on claims that Circuit Judge David Reynolds had failed to act promptly on pro se pleadings in two criminal cases filed against Petitioner. The Supreme Court requested an amended response on Petitioner's claims concerning the disposition of certain pro se pleadings in one of the cases. In that case, the Supreme Court had originally affirmed the judgment of conviction and reversed and remanded, ordering resentencing. However, the resentencing order was invalid. In response to the Supreme Court's request for an amended response, Judge Reynolds submitted a response to which he attached an amended sentencing order. Because the documentation reflected that a new resentencing order had been entered in the case, the judgment in the case was final, and any underlying motions, including Petitioner's pro se pleadings that were the remaining subject of his mandamus petition at issue, effectively received a disposition. Therefore, Petitioner's request for mandamus relief in regard to those claims was moot. View "Glaze v. Reynolds" on Justia Law