Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Arkansas Supreme Court
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After the Garland County elected treasurer, Jo West Taylor, had received monthly retirement checks for over a year from the Arkansas Public Employees Retirement System (APERS), the APERS executive director terminated Taylor's benefits. The APERS Board of Trustees upheld the decision, determining (1) Taylor had not terminated her employment and her benefits were thus forfeited, and (2) Taylor was ineligible to receive additional service credits after the time she began receiving benefits. The circuit court (1) affirmed the Board's determination that Taylor had failed to terminate her employment, but (2) reversed the Board's finding that Taylor was ineligible to receive additional service credit. Both parties appealed. The Supreme Court affirmed in part, reversed in part, and remanded with instructions to reinstate the Board's decision, holding that substantial evidence supported the Board's conclusions. View "Ark. Pub. Employees Ret. Sys. v. Taylor" on Justia Law

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The Arkansas Department of Community Correction (DCC) owned a prison complex in Jefferson County that was part of several tracts of state land annexed to the City of Pine Bluff in 1999. The property was automatically zoned as residential. In 2011, DCC, with the approval of the Board of Correction, decided to use three existing buildings on its property to house persons who had been granted parole. The City objected to DCC's adding transitional housing to its prison complex. The circuit court granted declaratory judgment and injunctive relief in favor of the City, concluding that Ark. Code Ann. 16-93-1603 acted as a waiver of sovereign immunity and that DCC was subject to the zoning laws of the City. The Supreme Court reversed, holding that the circuit court erred in concluding that the General Assembly intended to waive the State's sovereign immunity in section 16-93-1603, and therefore, the circuit court lacked jurisdiction to hear the City's petition pursuant to the doctrine of sovereign immunity. View "Ark. Dep't of Cmty. Corr. v. City of Pine Bluff" on Justia Law

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In 1999, Appellant was convicted of multiple felony-drug charges and sentenced to an aggregate life sentence. In 2012, Appellant filed a motion to vacate a void judgment. The circuit court denied the motion, determining that it did not have jurisdiction to consider the motion because the motion was an untimely petition under Ark. R. Crim. P. 37.1. Appellant appealed, asserting that the circuit court did have jurisdiction to consider his claim because he challenged the court's jurisdiction and a challenge to the court's jurisdiction can be raised as a matter of common law without regard to jurisdiction conferred by any statute or rule. The Supreme Court dismissed Appellant's appeal and declared the motion related to the appeal moot, holding that Appellant failed to establish that the circuit court had jurisdiction to consider his motion to vacate. View "Watts v. State" on Justia Law

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In 1996, Appellant pled guilty to multiple felony offenses. An aggregate sentence of 720 months' imprisonment was imposed. In 2012, Appellant filed a pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111. The trial court denied the petition, holding that the petition amounted to an untimely petition for postconviction relief under Ark. R. Crim. P. 37.1. Appellant appealed and filed two motions related to the appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that whether the petition was one under Rule 37.1 or under the statute, it was not timely filed, and the trial court did not therefore err in denying it. View "Purifoy v. State" on Justia Law

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Appellant pled guilty to theft by receiving, being a felon in possession of a firearm, and possession with intent to deliver a controlled substance. Appellant subsequently filed in the circuit court where he was incarcerated a pro se petition for a writ of habeas corpus, contending that the trial court lacked jurisdiction in his case because the felony information charging him with aggravated robbery was defective and that the State did not have jurisdiction over him. The Supreme Court dismissed the appeal and declared the motions Appellant filed in relation to the appeal moot, holding (1) because Appellant failed to properly object to the sufficiency of his indictment prior to trial, he did not establish that the information was defective; and (2) the trial court had jurisdiction over the proceedings. View "Murry v. Hobbs" on Justia Law

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This appeal arose from a medical helicopter accident in Arkansas. Employer was the owner and operator of the helicopter and provided air-ambulance services to the area. Nurse and EMT (collectively, Appellants) and Pilot (Appellee) were all employees of Employer. On the day of the accident, Appellants picked up the victim of an automobile accident in Arkansas, and Pilot piloted the helicopter toward the hospital. However, the helicopter crashed. Nurse and EMT brought a negligence suit against Pilot, alleging their injuries were caused by Pilot's negligent operation of the helicopter. The circuit court dismissed the suit based on the exclusive-remedy provision of the Workers' Compensation Act. Appellants appealed, and the case was transferred to the Arkansas Workers' Compensation Commission. The Arkansas Workers' Compensation Commission concluded that, at the time of the accident, Pilot was performing his employer's duty to provide a safe work place for Appellants and was therefore entitled to immunity under the workers' compensation statutes. The Supreme Court affirmed, holding that the Commission did not err in its findings of fact and conclusions of law. View "Miller v. Enders" on Justia Law

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Plaintiff was employed by a staffing company and had been contracted to work at Gates Rubber Company (Gates) when he suffered an injury to his arm and hand, including the severing of fingers. Plaintiff alleged that Total Compliance Consultants, Inc. (TCC) had contracted with Gates to consult on safety-compliance issues and that TCC either breached its contract or was negligent. The circuit court dismissed the complaint, concluding that Plaintiff was a third-party beneficiary of the contract between TCC and Gates but that TCC was not negligent and did not breach its contract. The Supreme Court affirmed, holding that Plaintiff's points on appeal were either not appealable or lacked merit. View "Meador v. Total Compliance Consultants, Inc." on Justia Law

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The State commenced criminal proceedings against Petitioner by filing an information charging him with second-degree sexual assault. Petitioner filed a pro se motion to dismiss the charge on the basis of a speedy-trial violation, and the circuit court denied the motion. Petitioner then filed a petition before the Supreme Court seeking to halt the proceedings on the basis that the time period in which to bring him to trial had expired. The Supreme Court denied the petition, holding that this was not an appropriate case for interlocutory review of the issue that Petitioner sought to raise, as the motion here was not denied on the merits of the issue presented but rather was denied because the trial court ruled that it would not consider the issues in the pro se motion. View "Kindall v. Circuit Court" on Justia Law

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Appellant was a prisoner serving a life sentence on a capital-murder conviction. Appellant filed a petition for writ of habeas corpus in the circuit court of the county where he was incarcerated, claiming that the process of service of the felony information charging him with the crime was constitutionally infirm. The circuit court denied the petition. Appellant lodged an appeal of the circuit court's order and filed a motion seeking an extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that Appellant's allegations of constitutional violations involving the process of charging him were not the type of error cognizable in a proceeding for the writ. View "Jones v. Hobbs" on Justia Law

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Petitioner filed in the circuit court in the county where he was incarcerated a pro se petition for writ of habeas corpus, alleging, among other claims, that he was denied the effective assistance of counsel. The circuit court dismissed the petition and denied Petitioner's motion for reconsideration. Petitioner appealed. The Supreme Court clerk declined to lodge the record-on-appeal for procedural reasons, and Petitioner filed a motion seeking leave to proceed with the appeal. The Supreme Court denied the motion, holding that Appellant failed to state cognizable claims and therefore did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Hooper v. Hobbs" on Justia Law