Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief without holding an evidentiary hearing, holding that there was no error.Petitioner was convicted of first-degree murder and sentenced to life imprisonment without parole. In his petition for postconviction relief, Petitioner alleged that his counsel was ineffective for failing to develop the defense of provocation, among other things. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court's finding that Petitioner did not receive ineffective assistance of counsel was not clearly erroneous. View "Coakley v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise allegations that warranted coram nobis relief.Petitioner was found guilty of the rape of his minor daughter and sentenced to life imprisonment. In his petition for coram nobis relief, Petitioner argued that his daughter had recanted her trial testimony, his daughter perjured herself, and his trial counsel was ineffective. The Supreme Court denied the petition, holding that Petitioner failed to establish that he was entitled to the writ. View "Chunestudy v. State" on Justia Law

The Supreme Court reversed the ruling of the circuit court denying the State's motion to dismiss this complaint alleging that Defendants, in their official capacities, had terminated him in violation of public policy without a name-clearing hearing, holding that sovereign immunity barred Plaintiff's claims.After Plaintiff was involuntarily terminated from his employment he filed suit for wrongful termination and alleged a violation of his right to due process for failure to provide a name-clearing hearing. Appellants moved to dismiss the complaint on grounds of sovereign immunity. The motion was denied. The Supreme Court reversed, holding that Plaintiff failed to plead sufficient facts that asserted an exception to the sovereign-immunity doctrine. View "Arkansas Department of Finance & Administration v. Lewis" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Plaintiff's employment discrimination complaint against Mercy Hospital Rogers, holding that the circuit court erred in dismissing Plaintiff's claim under the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108.Specifically, the Supreme Court held (1) Plaintiff failed to plead that Mercy made any false representations of material fact sufficient to sustain a fraud action; (2) because Plaintiff failed to state an exception to the at-will doctrine, the circuit court properly dismissed Plaintiff's wrongful termination claim; and (3) given the circuit court's lack of factual development on the issue, the Supreme Court cannot determine whether Mercy is a religious organization entitled to the ACRA religious-organization exemption, and therefore, remand was required. View "Jenkins v. Mercy Hospital Rogers" on Justia Law

The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law

The Supreme Court denied Petitioner's second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and seeking the appointment of postconviction counsel, holding that Petitioner failed to raise a cognizable claim for issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to a term of life imprisonment plus a term of 180 months. The Supreme Court affirmed. In the instant coram nobis petition, Petitioner argued that he was entitled to relief due to a coerced guilty plea, the failure of the prosecutor or his counsel to advise him of the spousal privilege in violation of Brady v. Maryland, 373 U.S. 83 (1963), and ineffective assistance of both trial counsel and postconviction counsel. The Supreme Court denied the writ and denied Petitioner's motion for appoint of counsel as moot, holding that Petitioner's claims were not cognizable in a coram nobis proceeding. View "Gordon v. State" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se civil rights complaint filed pursuant to the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108, in which he alleged that Arkansas Department of Correction (ADC) officials violated his constitutional rights, holding that the circuit court did not err in dismissing the complaint.Appellant sued Appellees in their official and individual capacities, alleging that they had violated his constitutional rights to free speech, free exercise of his religion, access to the court, due process, and equal protection. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that Appellees were immune from liability because Appellant failed to raise claims that demonstrated the deprivation of a constitutional right. View "Muntaqim v. Payne" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis alleging that he was denied effective counsel prior to his criminal trial and that this violation of his Sixth Amendment right entitled him to coram nobis relief, holding that Petitioner was not entitled to relief.Petitioner was convicted of two counts of capital murder and one count of second-degree murder and sentenced to life imprisonment without parole on the capital murder charges. Petitioner later filed his coram nobis petition, raising claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner's allegations of ineffective assistance of counsel did not support issuance of the writ of error coram nobis. View "Hall v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's claim for habeas relief on the grounds that Petitioner's allegations should have been raised at trial or in a timely petition under Ark. R. Crim. P. 37.1, holding that Petitioner failed to raise a claim for issuance of the writ.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner later filed his habeas corpus petition, arguing that his conviction was void because he was tried by an eleven-member jury. The circuit court dismissed the action. The Supreme Court affirmed, holding that Petitioner's claim constituted a due process claim that was not cognizable in a habeas proceeding and should have been raised on direct appeal or in a petition for postconviction relief. View "Phillips v. Culpepper" on Justia Law

The Supreme Court dismissed on direct appeal the order of the circuit court denying in part Monsanto Company's motion for judgment on the pleadings and concluding that the Arkansas State Plant Board's Regulation 7 does not violate the Commerce Clause of the federal Constitution and is not invalid as being enacted by an unconstitutionally appointed board, holding that the circuit court did not err.The circuit court denied Monsanto's motion challenging the constitutionality of Regulation 7 and further granted judgment in favor of Monsanto on its claim that Ark. Code Ann. 2-16-206, the statute governing appointment of Board members, is an unconstitutional delegation of the appointment power. The Supreme Court dismissed on direct appeal and affirmed on cross-appeal, holding (1) the circuit court did not err in ruling that Regulation 7 does not violate the Commerce Clause or in rejecting Monsanto's argument that Regulation 7 was enacted by an unconstitutionally appointed board; and (2) the circuit court properly ruled that section 2-16-206(a)(5)-(13) is an invalid delegation of the appointment power. View "Monsanto Co. v. Arkansas State Plant Board" on Justia Law