Justia Arkansas Supreme Court Opinion Summaries

Appellant was an inmate in the Department of Correction serving a life sentence. Appellant filed a complaint against the governor, the chairman of the parole board, and the chairman of the board of correction seeking a declaratory judgment, injunctive relief against Defendants for civil-rights violations, and relief as a taxpayer for an illegal exaction based on claims concerning the procedures for submission of applications for clemency. The circuit court dismissed the complaint for failure to state a claim upon which relief may be granted. Appellant appealed and filed motions related to his appeal. The Supreme Court denied the motions and affirmed the circuit court's dismissal of the complaint, holding that the court did not abuse its discretion in concluding that Appellant failed to state a claim on the three bases that Appellant raised in this appeal. View "Holloway v. Beebe" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder and first-degree battery and failure to stop after an accident with injury or death. Appellant appealed, contending that the trial court erred by refusing to instruct the jury on the offense of felony manslaughter, which he argued was a lesser-included offense of felony murder. In so arguing, Appellant contended that although Perry v. State and Hill v. State supported the trial court's ruling, those cases ignored Ark. Code Ann. 5-2-203(b). The Supreme Court affirmed, holding (1) the Court would not accept Appellant's invitation to overrule Perry and Hill; and (2) the Court's felony-murder jurisprudence is in concert with the legislature's mandate stated in section 5-2-203(b). View "Holian v. State" on Justia Law

Petitioner was convicted of eleven counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. The court imposed an aggregate sentence of 108 months' imprisonment. Petitioner did not appeal the sentencing order and subsequently sought leave to proceed with a belated appeal. In his motion, Petitioner asserted that his appointed attorney did not provide effective assistance of counsel and that the evidence was insufficient to sustain the judgment. The Supreme Court denied the motion, holding that Petitioner did not demonstrate good cause to permit him to proceed with a belated appeal, as Petitioner's allegation concerning his attorney's effectiveness at trial and his claim of actual innocence were not matters to be addressed in a proceeding for a belated appeal. View "Davis v. State" on Justia Law

Petitioner was convicted of three counts of rape and three counts of terroristic threatening. The convictions were affirmed on direct appeal. Petitioner subsequently filed a petition for postconviction relief, which was denied. Thereafter, Petitioner filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that the prosecution withheld evidence of reports and transcripts of the victims' statements and that this was a violation of Brady v. Maryland. The Supreme Court denied the writ, holding that Petitioner did not establish a Brady violation because Petitioner's claim that the materials were not made available to his defense did not appear meritorious. View "Sparks v. State" on Justia Law

Appellant was convicted of rape and sentenced to 300 months' imprisonment. The Supreme Court affirmed Appellant's conviction and sentence, holding that the circuit court did not err in (1) denying Appellant's motion in limine to suppress statements he made to his psychotherapist and the medical records pertaining to his treatment, as the argument was not preserved for appellate review; and (2) granting the State's motion in limine to exclude any instance of abuse that might have occurred after the victim turned fourteen years old, as Appellant failed to preserve his argument that the evidence would have been relevant and admissible to impeach the victim's credibility. View "Riley v. State" on Justia Law

When Cody Metheny underwent brain surgery, the physician (Doctor) mistakenly operated on the wrong side of his brain. Fifteen months later, Cody's parents (the Methenys) learned tissue had been removed from the wrong side of Cody's brain. The Methenys filed a direct-action suit, alleging medical negligence on the part of Hospital where Doctor practiced and against Hospital's liability-insurance carrier (Insurer). The jury returned a verdict in favor of the Methenys. Insurer appealed, arguing that the circuit court erred in (1) failing to instruct the jury in a manner that would allow it to apportion liability among it and certain physicians who were sued in a prior case but ultimately settled; (2) refusing to allow Insurer to present evidence of fault attributable to the settling physicians; and (3) denying Insurer's motion for judgment notwithstanding the verdict where the evidence supporting Cody's future damages was based on improperly bundled calculations. The Methenys cross-appealed the circuit court's order reducing the jury's verdict from $20 million to $11 million. The Supreme Court affirmed on direct appeal and cross-appeal, holding that the circuit court did not err in its judgment. View "ProAssurance Indem. Co. v. Metheny" on Justia Law

Petitioner was convicted of two counts of rape and sentenced to an aggregate sentence of 480 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, alleging that he was not afforded effective assistance of counsel at trial. The Supreme Court denied the petition, holding that Petitioner's allegation was outside the purview of a coram-nobis proceeding, and to the extent that Petitioner may have intended his claims to be an attack on the sufficiency of the evidence or the credibility of witnesses, such issues were also not cognizable in coram-nobis proceedings. View "McDaniels v. State" on Justia Law

LVNV Funding, LLC filed a complaint against Rae Nardi for an amount due on her credit card account with Citibank. LVNV claimed, as an assignee, it had a contractual relationship between Nardi and Citibank and a cause of action for recovery of the amount due on the account. Nardi filed a motion for summary judgment, alleging that the failure to attach to the complaint a copy of the agreement between Nardi and Citibank constituted a violation of Ark. R. Civ. P. 10(d). The circuit court granted summary judgment for Nardi, finding that LVNV violated Rule 10(d), which requires that a copy of the "instrument or document" upon which the claim is based be attached to the complaint. The Supreme Court affirmed, holding that compliance with Rule 10(d) is mandatory, and therefore, entry of summary judgment was proper. View "LVNV Funding, LLC v. Nardi" on Justia Law

Appellant was convicted of delivery of a controlled substance and sentenced to an enhanced sentence of forty years' imprisonment and a fine. The Supreme Court affirmed on appeal. Appellant subsequently filed a petition for postconviction relief and, later, a motion to correct an illegal sentence. Both requests were denied. Thereafter, Appellant filed a pro se petition for writ of habeas corpus raising double-jeopardy claims. The circuit court denied the petition. Appellant appealed and filed with the Supreme Court a motion for extension of time in which to file his brief. The Court dismissed the appeal and declared the motion moot, holding that Appellant's claims were not cognizable in a petition for habeas corpus. View "Khabir v. Hobbs" on Justia Law

Appellants in this case were three companies engaged in providing cable-television services to subscribers (collectively, "Charter"). In a consolidated petition for review, Charter challenged the Tax Division of Appellee Arkansas Public Service Commission's ad valorem assessments of its properties for the tax years 2006 through 2009. The Commission upheld the Tax Division's assessments, and the circuit court affirmed. Charter appealed, arguing (1) the assessments were erroneous because they included the valuation of intangible personal property, which it claimed was exempt from taxation, and (2) the assessment of intangible property was illegal because the tax Division failed to promulgate rules that would provide notice of the change to taxpayers. The Supreme Court affirmed, holding (1) the Commission did not err by assessing the value of Charter's intangible personal property because the relevant statutes require the assessment of a cable-television company's intangible personal property, and the exemption provision exempting the taxation of intangible personal property did not apply; and (2) the Court was precluded from addressing Charter's second issue on appeal. View "Falcon Cable Media LP v. Ark. Pub. Serv. Comm'n" on Justia Law