Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court held that Ark. Code Ann. 12-9-301, which provides immunity from both suit and liability for certain officials "except to the extent that they have be covered by liability insurance," does not apply to a federal cause of action brought under 42 U.S.C. 1983 but does apply to a state claim brought under the Arkansas Civil Rights Act.Plaintiff filed a complaint against the Benton School District, a principal in the strict (Lori Bacon), and an assistant superintendent (Lisa Gattis). The district court concluded that all Defendants were liable under section 1983 and the Arkansas Civil Rights Act for violating Plaintiff's rights to free speech and to petition the government under the First Amendment. The court granted Bacon and Gattis's motion for summary judgment on qualified immunity grounds but determined that their motion was limited to the extent they were covered by liability insurance. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) section 21-9-301 does not impact a claim brought under section 1983; and (2) the circuit court correctly ruled that section 21-9-301 immunity applies to claims arising under the Arkansas Civil Rights Act. View "Benton School District v. Greer" on Justia Law

The Supreme Court affirmed Defendant's conviction, rendered after a jury trial, of capital murder and his sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held that the circuit court (1) did not err by denying Defendant's motions to suppress evidence from the traffic stop because law enforcement had reasonable suspicion that Defendant was a felon in possession of a firearm; (2) did not err in denying Defendant's motions to suppress evidence from his detention and arrest because the same facts that provided reasonable suspicion for the initial stop provided reasonable suspicion for his pat-down and arrest; and (3) did not err by permitting the State to introduce videos containing statements made by law enforcement officers. View "Bishop v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court concluding that the Arkansas Racing Commission's (ARC) decision to award the Pope County casino license to Cherokee Nation Business, LLC (CNB) and Legends Resort and Casino, LLC (Legends) was a "legal nullity, void and of no effect," holding that there was no error.Gulfside Casino Partnership sought a declaratory judgment that the ARC's actions in awarding the license to CNB and Legends were unconstitutional, constituted and ultra vires act, and violated the Administrative Procedure Act. The circuit court granted summary judgment for Gulfside, ruling that the ARC acted ultra vires, in violation of amendment 100 to the Arkansas Constitution. The Supreme Court affirmed, holding that the ARC acted ultra vires in issuing the license to CNB. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of rape, three counts of first-degree sexual assault, and two counts of sexual indecency with a child and sentencing him to two terms of life imprisonment, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the circuit court abused its discretion by admitting testimony of a certain witness under the pedophile exception to Ark. R. Evid. 404(b). The Supreme Court affirmed, holding (1) Defendant's first argument was not preserved for appellate review; (2) Defendant's argument that the circuit court erred in denying his motion for a mistrial was not preserved; and (3) the circuit court did not err in excluding evidence of the victims' prior sexual conduct pursuant to the rape-shield statute set forth in Ark. Code Ann. 16-42-101(c). View "Wilder v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and his sentence to life in prison, holding that substantial evidence supported the conviction.After a jury trial, Defendant was convicted of the murder of his ex-wife and sentenced to life imprisonment. As his sole point on appeal, Defendant argued that there was insufficient evidence supporting his conviction, and therefore, the trial court erred in denying his motion for a directed verdict. The Supreme Court disagreed and affirmed, holding that there was substantial evidence to support Defendant's capital murder conviction, and there was no error with respect to the jury's rejection of Defendant's affirmative defense argument. View "Wofford v. State" on Justia Law

The Supreme Court denied a petition for writ of certiorari and/or prohibition requesting relief from the Court after the circuit court denied Petitioner's motions to dismiss the charges against him, holding that an extraordinary writ was not necessary in this case.Petitioner, who was charged with aggravated robbery and other charges, moved to dismiss the charges for a violation of his right to a speedy trial pursuant to Ark. R. Crim. P. 28.1, asserting that he was not brought to trial within twelve months from the date of his arrest. Petitioner also filed a motion to dismiss for lack of jurisdiction, alleging that the juvenile division retained exclusive jurisdiction. The circuit court denied both motions. The Supreme Court denied Petitioner's ensuing petition for writ of certiorari and/or prohibition, holding that the circuit court did not err in denying Petitioner's motions to dismiss for lack of jurisdiction and for violation of his speedy-trial rights. View "Tilson v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court's failure to instruct the jury with the model verdict form on dispute accomplice status was reversible error under the third and fourth exceptions enumerated in Wicks v. State, 606 S.W.2d 366 (Ark. 1980). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence obtained during a search of his property; and (2) neither Wicks exception to the objection requirement applied under the circumstances of this case. View "Nowell v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioner's petition for writ of mandamus or other supervisory writ, granting a motion for judgment on the pleadings filed by the Arkansas Game and Fish Commission and its director (collectively, AGFC) and dismissing Petitioner's complaint for declaratory judgment and injunctive relief, holding that there was no error.Petitioner brought this complaint seeking a declaration that holders of an Enhanced Concealed Carry License (ECCL) may carry concealed firearms in AGFC buildings and facilities, a declaration that AGFC illegally refused to permit his entrance, and an injunction prohibiting AGFC from denying ECCL holders entrance into AGFC buildings with firearms. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court properly denied Petitioner's motion for summary judgment and granted AGFC's motion for judgment on the pleadings. View "Corbitt v. Ark. Game & Fish Comm'n" on Justia Law

The Supreme Court affirmed the judgment of the circuit court admitting two 911 calls reporting a shooting and a dash cam video containing statements from an eyewitness during Defendant's criminal trial, holding that any error was harmless.After a jury trial, Defendant was convicted of first-degree murder, first-degree battery, and other crimes. After he was sentenced to life imprisonment plus fifteen years, Defendant filed a motion for a mistrial, which was deemed denied. The Supreme Court affirmed, holding (1) the circuit court properly ruled that the statements from the 911 calls were nontestimonial and thus admissible; (2) the circuit court erred in admitting the dash cam video, but the error was harmless beyond a reasonable doubt; and (3) Defendant's final two arguments were not preserved for appellate review. View "McNeil-Lewis v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Appellant of first-degree murder and other crimes and sentencing him to an aggregate term of two life sentences plus 835 years' imprisonment, holding that the State failed to demonstrate that Appellant was brought to trial within the twelve-month period required by Ark. R. Crim. P. 28.1(b).At issue on appeal was whether Appellant's constitutional right to a speedy trial, as embodied in Ark. R. Crim. P. 28.1, was violated when the State failed to bring him to trial within twelve months of the date of his arrest. The Supreme Court concluded that Appellant's right was indeed violated because he was held for a total of 405 days during which the speedy trial was not tolled, a total that exceeded the requisite 365-day period. View "Parker v. State" on Justia Law