Justia Arkansas Supreme Court Opinion Summaries

Husband and Wife had been married for more than twenty years when Husband filed for divorce. The parties were co-owners of Brave New Restaurant. After the circuit court entered a divorce decree, Husband appealed, contending that the circuit court committed reversible error by (1) dividing the goodwill in the restaurant, and (2) “double dipping” into the stream of his future income when it divided the goodwill of the restaurant and gave Wife alimony. The Supreme Court affirmed the judgment of the circuit court, holding that the circuit court (1) did not err in concluding that the goodwill was corporate goodwill and dividing it as martial property rather than concluding that it was personal to Husband; and (2) did not abuse its discretion in awarding alimony to Wife after finding that the goodwill in this case was corporate goodwill. View "Brave v. Brave" on Justia Law

Appellant was charged with murder in the first degree. Before trial, Appellant gave notice that he intended to assert the affirmative defense of a lack of capacity as a result of mental disease or defect and provided the State with a report by Dr. Bradley Diner, a psychiatrist. The circuit court granted the State’s motion in limine to exclude Dr. Diner’s testimony as it related to mental disease or defect. Defendant was subsequently convicted of murder and sentenced to life imprisonment without parole. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion by granting the State’s motion in limine and disallowing the opinion of Dr. Diner. View "Bowden v. State" on Justia Law

Mary Berryhill sued Frances Synatzke, alleging that Synatzke was responsible for a car accident between Berryhill and Synatzke. Berryhill also sued seventy John Does, including a John Doe that was designated to represent the estate of any defendant who predeceased the service of the complaint. At the time the complaint was filed, however, Synatzke had died. After the statute of limitations had passed, Berryhill filed an amended complaint naming Synatzke’s estate as a party. The estate filed a motion for summary judgment asserting that the original complaint was a nullity because Synatzke had died prior to the filing of the original complaint, and therefore, the complaint could not be transformed into a valid suit by amending the complaint after the statute of limitations had passed. The circuit court granted summary judgment for the estate. The Supreme Court reversed, holding (1) because the identity of the tortfeasor, the estate, was unknown to Berryhill at the time she filed her original complaint, Ark. Code Ann. 16-56-125 was applicable to her claim and tolled the statute of limitations; and (2) because there was a valid pleading to relate back to, the real party, the estate, could be substituted for the John Doe defendant in the original complaint. View "Berryhill v. Synatzske" on Justia Law

Appellant entered a negotiated plea of guilty to murder in the first degree and was sentenced to 480 months’ imprisonment. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that his trial counsel was ineffective for, among other things, not advising him that he would not be eligible for parole until he had served seventy percent of his sentence. The trial court denied Appellant’s petition after an evidentiary hearing. The Supreme Court dismissed Appellant’s appeal and mooted the motion Appellant filed asking for counsel to be appointed to represent him, holding that the trial court did not err in denying relief on Appellant’s claims. View "Barber v. State" on Justia Law

After a jury-waived trial, Appellant was found guilty of capital murder, among other crimes. Appellant was sentenced to life imprisonment without the possibility of parole on the capital-murder charge. Appellant appealed, arguing that the circuit court erred in denying his motions for a directed verdict because the evidence was not sufficient to establish that he acted with the requisite intent of premeditation and deliberation. The Supreme Court agreed and reversed Defendant’s conviction for capital murder, holding that the circuit court engaged in speculation in determining that Appellant acted with premeditation and deliberation and improperly shifted the burden of proof when weighing the evidence. View "Thornton v. State" on Justia Law

Plaintiffs filed suit against the United States pursuant to the Federal Tort Claims Act (“FTCA”), alleging that the negligence of the United States Forest Service caused the death of several campers, who were camping in or near the Albert Pike Recreation Area and were caught in a flood caused by a rapid rise in the Little Missouri River and its tributaries. The United States asserted the subject-matter jurisdiction was lacking under the FTCA because the Arkansas Recreational Use Statute provided the government with immunity. Plaintiffs alleged that the United States was not immune from liability because it "maliciously" failed to warn or guard against an ultrahazardous condition of which it knew to be dangerous. The United States district court certified a question of law to the Arkansas Supreme Court, which answered by holding that “malicious” conduct under Ark. Code Ann. 18-11-307(1) includes conduct in reckless disregard of the consequences from which malice may be inferred. View "Roeder v. United States" on Justia Law

Appellant was convicted of first-degree murder and committing a felony with a firearm and sentenced to 420 months’ imprisonment, including a statutory enhancement. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which the trial court denied. After Appellant appealed from the denial of his petition, Appellant filed a pleading titled “petition to reinvest jurisdiction,” seeking to have the Supreme Court return jurisdiction to the trial court so that he could obtain a ruling on issues not addressed in the order denying postconviction relief. The Supreme Court (1) denied the petition to reinvest jurisdiction for failing to comply with the procedural rules, and (2) dismissed Appellant’s appeal because Appellant indicated that he did not believe the appeal had merit unless he was permitted to obtain the additional rulings and because he did not file a brief in support of his appeal within the time permitted. View "Plessy v. State" on Justia Law

Petitioner filed a pro se petition for writ of error coram nobis, which the circuit court dismissed. The record established that Petitioner did not file a timely notice of appeal from the order. Petitioner subsequently sought leave to proceed with a belated appeal. The Supreme Court denied the motion, holding that Petitioner did not establish good cause for his failure to perfect an appeal in a timely manner because his bare statement that he filed a notice of appeal was not sufficient cause to permit the appeal to go forward. View "Kennel v. State" on Justia Law

After a jury trial, Appellant was found guilty of one count of rape of his biological daughter and sentenced to life imprisonment. The Supreme Court affirmed on appeal. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging that he was entitled to relief based on ineffective assistance of counsel and related trial errors. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding the record did not support the allegations, the allegations were without merit or conclusory, and Appellant was otherwise not entitled to relief on his claims. View "Breeden v. State" on Justia Law

In 2004, Appellant was found guilty of aggravated robbery and theft of property and sentenced to 264 months’ imprisonment. In 2013, Appellant filed a pro se petition for writ of habeas corpus, alleging that the judgment-and-commitment order in his case was void because he was not afforded due process of law. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant’s assertion of a denial of due process was a claim of trial error, and as such, Appellant’s claim was not sufficient to implicate the facial validity of the judgment or the jurisdiction of the trial court. View "Watson v. State" on Justia Law