Justia Arkansas Supreme Court Opinion Summaries

Mike Burcham filed an action against the University of Arkansas and others, claiming that he was wrongfully terminated. The University filed an amended motion to dismiss, arguing that Burcham’s complaint was barred by sovereign immunity. The circuit court denied the motion, concluding that an allegation in Burcham’s complaint that the University failed to follow a grievance procedure outlined in the employee handbook was sufficient to waive the University’s sovereign immunity. The Supreme Court reversed, holding that none of the exceptions to sovereign immunity were applicable to the instant case, and therefore, the circuit court erred in denying the University’s amended motion to dismiss. View "Bd. of Trs. v. Burcham" on Justia Law

Petitioner pleaded guilty to two counts of second-degree sexual assault. Petitioner subsequently filed in the trial court a pro se petition for writ of error coram nobis alleging that his guilty plea was coerced and that newly discovered evidence warranted issuance of the writ. The circuit court denied the petition. Petitioner later sought leave to proceed with a belated appeal of the order. The Supreme Court denied the motion, holding that the trial court did not abuse its discretion in denying coram nobis relief where (1) Petitioner’s claims did not rise to the level of coercion required to demonstrate that a writ of error coram nobis should issue; and (2) the petition did not demonstrate a Brady violation in that there was no fact cited by Petitioner that could not have been known at the time the plea was entered. View "Bannister v. State" on Justia Law

In 1991, Appellant was convicted and sentenced to death for the murders of Charles and Nancy Brannon. The circuit court later vacated Appellant’s convictions and sentences, finding that the prosecution’s failure to reveal information about one of its witnesses prejudiced Appellant’s right to a fair trial. Appellant was retried for the murders in 2012, was against convicted of both counts of capital murder, and was sentenced to life without parole. The Supreme Court affirmed, holding that the circuit court did not err by (1) permitting Byron Hopes to testify because although his testimony was procured through an illegal sentence reduction, the proper remedy was cross-examination of the witness, not suppression of the testimony; (2) holding that the cross-examination of Hopes about the deal would open the door to testimony about Appellant's other murder case; (3) finding that transcripts of witness testimony from Appellant's first trial were admissible in his new trial; and (4) excluding part of the prior testimony of Bill Keeling, whose testimony was previously proffered but rejected in Appellant's first trial. View "Sanders v. State" on Justia Law

After a jury trial, Appellant was convicted of thirty-seven various sex offenses and sentenced to a total of thirty-seven years incarceration. After Appellant’s convictions were affirmed on appeal, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that his trial counsel was ineffective for because counsel was simultaneously representing Appellant and Appellant’s wife at the time of Appellant’s trial, and the dual representation created an actual conflict of interest adversely affecting counsel’s performance. The trial court ultimately denied the petition. The Supreme Court reversed, holding (1) an actual conflict of interest existed under the circumstances of this case; and (2) the actual conflict of interest adversely affected counsel’s performance. Remanded for a new trial with conflict-free counsel. View "Rackley v. State" on Justia Law

After a jury trial in 2008, Petitioner was found guilty of aggravated robbery and burglary. Petitioner’s motion for a new trial and petition for postconviction relief were denied. Petitioner subsequently filed a petition requesting that the Supreme Court reinvest jurisdiction in the trial court in order that he may proceed with a petition for writ of error coram nobis, claiming (1) his trial counsel was ineffective, (2) newly discovered evidence existed that questioned the credibility of the State’s witnesses, and (3) evidence was withheld by the prosecuting attorney’s office in violation of his constitutional rights, as recognized in Brady v. Maryland. The Supreme Court denied the writ, holding (1) Petitioner’s first two allegations were not a basis for the writ; and (2) Petitioner’s claims of a Brady violation were without merit. View "Burton v. State" on Justia Law

Appellant pleaded guilty to multiple counts of aggravated robbery and theft of property and was sentenced to an aggregate sentence of life imprisonment. Almost twenty years after the judgment had been entered, Appellant filed a pro se petition for writ of error coram nobis. The trial court denied the petition, concluding that the claims were either without merit or not within the purview of a coram-nobis proceeding and that Appellant did not act with due diligence in filing the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the coram-nobis petition. View "Wright v. State" on Justia Law

After a jury trial, Appellant was found guilty of four counts of sexual assault of a fourteen-year-old boy. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for postconviction relief, claiming dissatisfaction with the trial judge, trial error, and ineffective assistance of counsel. The trial court denied the petition. The Supreme Court dismissed Appellant’s appeal and mooted Appellant’s motion for extension of time to file his brief-in-chief, holding (1) the allegations concerning the judge’s conduct did not rise to a showing of fundamental error sufficient to void the judgment; (2) Appellant failed to establish that his attorney was ineffective; and (3) Appellant did not establish that any claim of trial error raised in the petition was sufficient to void the judgment in his case. View "Nelson v. State" on Justia Law

In 1986, Petitioner was found guilty of three felony offenses for which the circuit court imposed an aggregate sentence of life imprisonment. The Supreme Court affirmed. In 2013, Petitioner filed a pro se petition for leave to proceed in the trial court pursuant to Ark. R. Crim. P. 37.1. The Supreme Court held that none of Petitioner’s claims was sufficient to void the judgment-and-commitment order and denied the petition. Petitioner subsequently filed a second Rule 37.1 petition, alleging several claims of error that were raised in his original Rule 37.1 petition. The Supreme Court dismissed the petition, holding that Petitioner did not raise a claim sufficient to void the judgment in his case. View "Munnerlyn v. State" on Justia Law

Appellee, who was seventeen years old at the time of the offenses, pled nolo contedere to committing several crimes, including kidnapping. The circuit court sentenced Appellee to life imprisonment for his kidnapping conviction. The U.S. Supreme Court subsequently issued its decision in Graham v. Florida, holding that the Eighth Amendment forbids a sentence of life without parole for a juvenile offender who did not commit homicide. Appellee subsequently filed a writ of habeas corpus alleging that, pursuant to Graham, his life sentence was unconstitutional. After a sentencing hearing, the circuit court sentenced Appellee to a term of forty years’ imprisonment for the kidnapping conviction. The State appealed, arguing that the circuit court erred in not sentencing Appellee to a term of life imprisonment with the possibility of parole. Appellee cross-appealed. The Supreme Court affirmed, holding (1) the circuit court correctly ruled that the maximum sentence available after invalidation of Appellee’s life sentence was forty years; and (2) Graham did not entitle Appellee to additional consideration of his youth or the circumstances of his crime to reduce his sentence even further. View "Hobbs v. Turner" on Justia Law

After a jury trial, Appellant was found guilty of possession of a controlled substance with intent to deliver. Appellant later filed a pro se petition for writ of habeas corpus, contending (1) he was subjected to an illegal search and seizure of evidence and an illegal arrest, and (2) insufficient evidence supported the judgment as revealed in contradictory testimony of witnesses at trial. The circuit court denied the petition. The Supreme Court dismissed the appeal and declared moot the motion filed in relation to the appeal, holding that Appellant failed to raise a claim within the purview of a habeas action and thus failed to meet his burden of demonstrating a basis for a writ of habeas corpus to issue. View "Green v. State" on Justia Law