Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Arkansas Supreme Court
Pitts v. State
After a jury trial, Petitioner was found guilty of second-degree sexual assault and sexual indecency with a child. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, asserting several grounds for the writ. The Supreme Court denied the petition, holding that not only did Petitioner not present sufficient grounds to support issuance or the writ, but his failure to act with due diligence, alone, would constitute good cause to deny the petition. View "Pitts v. State" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Philyaw v. State
After a jury trial in 1981, Petitioner was found guilty of aggravated robbery and sentenced to life imprisonment. Petitioner later filed a petition in the Supreme Court requesting that jurisdiction be reinvested in the trial court so that he may proceed with a petition for writ of error coram nobis, contending that he was deprived of due process and his right to trial by an impartial jury and that his counsel provided ineffective assistance at trial. The Supreme Court denied the petition, holding that the sole claim raised in the petition that could fit within the bounds of a coram-nobis proceeding was the assertion of a Brady violation, but none of evidence set forth by Petitioner in support of his claim rose to the level of a Brady violation. View "Philyaw v. State" on Justia Law
Ortho-McNeil-Janssen Pharms., Inc. v. State
In 1993, Appellants developed Risperdal, a second-generation, or atypical, antipsychotic medication, which was considered highly beneficial in treating schizophrenia patients. In 2007, the State filed suit against Appellants, alleging that Appellants (1) knowingly made false statements or representations of material fact in their Risperdal label in violation of the Arkansas Medicaid Fraud False Claims Act (“MFFCA”); and (2) violated the Arkansas Deceptive Trade Practices Act (“DTPA”) by distributing a promotional letter to Arkansas healthcare providers that contained “false, deceptive, or unconscionable statements.” A jury found that Janssen violated the MFFCA and the DTPA by failing to comply with federal labeling requirements and imposed civil penalties totaling $11,422,500. The Supreme Court (1) reversed and dismissed the MFFCA claim, as Appellants were not healthcare facilities or applying for certification as described by the statute; and (2) reversed and remanded the DTPA claim, holding that the circuit court abused its discretion in admitting certain hearsay into evidence. View "Ortho-McNeil-Janssen Pharms., Inc. v. State" on Justia Law
Montgomery v. State
Appellant was convicted of the rape of his six-year-old granddaughter and sentenced to twenty-five years’ imprisonment. Following his unsuccessful appeal, Appellant filed a petition for postconviction relief, alleging that his trial counsel rendered ineffective assistance of counsel. The circuit court denied the petition, but the Supreme Court reversed for a hearing. After a hearing, the circuit court again denied relief. The Supreme Court reversed and remanded for a new trial, holding that Appellant was prejudiced by his trial counsel’s failure to object to testimony given by a social worker, which included the social worker’s impermissible opinion on the child victim’s truthfulness and the credibility of the victim’s claims. View "Montgomery v. State" on Justia Law
Davis v. State
After a jury trial in 1988, Appellant was convicted of capital murder, aggravated robbery, and theft of property. Appellant was sentenced to life imprisonment for the murder conviction. In 1991, Appellant’s convictions for aggravated robbery and theft of property were set aside. In 2012, Appellant filed a pro se petition for writ of habeas corpus, alleging trial error and ineffective assistance of counsel claims and that the trial court lacked jurisdiction because it entered an amended judgment. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant’s petition did not establish the facial invalidity of the judgment or demonstrate a lack of the trial court’s jurisdiction, and therefore, Appellant did not establish a basis for a writ of habeas corpus to issue. View "Davis v. State" on Justia Law
Britt v. State
After a jury trial, Appellant was found guilty of several offenses, including first-degree murder. The case was reversed and remanded. After a retrial, Appellant was again found guilty of first-degree murder and related offenses. Appellant was sentenced to life imprisonment for the first-degree murder conviction. Appellant later filed a pro se petition for writ of habeas corpus, arguing that his life sentence for the murder conviction was illegal because he was a juvenile at the time of the crime. The circuit court dismissed the petition on the grounds that it did not conform to pleading rules. The Supreme Court dismissed Appellant’s appeal and mooted the motions filed in relation to the appeal, holding that, pursuant to Murry v. Hobbs, because Appellant’s life sentence for first-degree murder was not mandatory, this sentence was not illegal under Miller v. Alabama. View "Britt v. State" on Justia Law
Armstrong v. State
After a jury trial, Appellant was found guilty of committing two counts of Class Y felony terroristic acts, four counts of Class B felony terroristic acts, and two counts of battery in the first degree. The court of appeals affirmed. Appellant subsequently filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging trial error and that his attorney provided ineffective assistance. The trial court denied the petition without a hearing. Appellant appealed, arguing that the trial court erred in denying the petition without a hearing. The Supreme Court affirmed, holding that the trial court did not err in denying relief without holding a hearing. View "Armstrong v. State" on Justia Law
Grant v. Hobbs
After a jury trial in 2003, Appellant was found guilty of capital murder and first-degree battery and sentenced to an aggregate term of life imprisonment without parole. In 2013, Appellant filed a pro se petition for declaratory judgment pursuant to Ark. Code Ann. 16-111-102 seeking to overturn the judgment by challenge the sufficiency of the evidence, claiming he was denied his due process rights, and alleging trial error. The circuit court dismissed the petition, concluding that Appellant had not stated a ground for declaratory judgment. The Supreme Court dismissed the appeal and declared the motions filed in relation to the appeal moot, holding that Appellant’s attempt to convert the declaratory-judgment statute into a postconviction remedy was not founded on proper procedure. View "Grant v. Hobbs" on Justia Law
Posted in:
Arkansas Supreme Court, Criminal Law
Valley v. Pulaski County Circuit Court
The Legislative Auditor subpoenaed Appellant to appear and testify during a meeting of the Legislative Joint Auditing Committee’s Standing Committee on Counties and Municipalities, but Appellant failed to appear. The Auditor subsequently filed a petition for adjudication of contempt. The circuit court eventually entered an order finding Appellant guilty of criminal contempt and issued a $250 fine. The Supreme Court affirmed, holding that the circuit court did not err (1) in denying Appellant’s motion to dismiss for lack of service pursuant to Ark. R. Civ. P. 4; (2) in ruling that the subpoena was a valid subpoena; and (3) in finding Appellant in criminal contempt. View "Valley v. Pulaski County Circuit Court" on Justia Law
Thornton v. State
After a jury trial, Appellant was found guilty of aggravated residential burglary and use of a firearm in the commission of the offense. Appellant subsequently filed a pro se petition for postconviction relief, alleging that his trial counsel provided ineffective assistance. The trial court denied the petition without a hearing. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of stating facts that affirmatively supported his claims of prejudice, and accordingly, the trial court did not err in denying relief; and (2) the trial court did not err in denying the petition without an evidentiary hearing. View "Thornton v. State" on Justia Law