Justia Arkansas Supreme Court Opinion Summaries

Appellant appealed from a circuit court order reflecting his convictions for capital murder and aggravated robbery and his sentence to life imprisonment without parole. Appellant's sole assertion on appeal was that the circuit court erred in refusing to hear testimony from a juror in support of his motion for new trial based on Ark. R. Evid. 606(b). The Supreme Court affirmed Appellant's convictions and sentence, holding that the circuit court did not abuse its discretion in prohibiting the testimony and denying Appellant's motion for new trial, as Rule 606(b) states plainly that a juror may not testify as to the effect of anything upon his mind as influencing him to assent to the verdict. View "Arnold v. State" on Justia Law

Petitioner Jason Winbush was found guilty by a jury of murder in the first degree and sentenced to 540 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Petitioner's sole ground for the writ was the claim that the evidence adduced at trial was insufficient to sustain the judgment. The Supreme Court denied the writ, holding that the issue was not cognizable in a coram-nobis proceeding and, rather, was a matter to be settled on direct appeal. View "Winbush v. State" on Justia Law

Petitioner was found guilty by a jury of murder in the first degree in the stabbing death of Gabino Mendoza. Petitioner was sentenced to life imprisonment. The Supreme Court affirmed. Petitioner subsequently filed a petition with the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, claiming (1) the prosecution violated his right to due process by coercing three persons into making false statements and that the three later provided affidavits attesting to the coercion, and (2) his attorney did not afford him effective assistance of counsel. The Supreme Court affirmed, holding that Petitioner's claims did not state a basis for the writ. View "Rodriguez v. State" on Justia Law

Following her resignation as a dental assistant in the dental office of Appellee, Appellant sued Appellee for sexual harassment and outrage. On remand, the circuit court granted Appellee's motion for partial summary judgment, concluding that Appellant's state-law claim for sexual harassment failed because the material facts established that Appellee did not have enough employees for a cause of action to exist against him pursuant to the Arkansas Civil Rights Act (ACRA). On interlocutory appeal, Appellant claimed the numerosity requirement of the ACRA violated the state and federal Constitutions. The Supreme Court dismissed without prejudice Appellant's appeal, holding that the circuit court's order was not final and appealable because it did not satisfy the requirements of Ark. R. Civ. P. 54(b). View "Pepper v. Garrett" on Justia Law

A jury convicted Appellant of aggravated residential burglary, aggravated robbery, kidnapping, terroristic threatening in the first degree, and battery in the second degree. Appellant appealed, arguing that the trial court erred in (1) denying his motion for a directed verdict to reduce the kidnapping charge from a Class Y felony to a Class B felony, and (2) admitting testimony concerning his previous uncharged conduct. The Supreme Court affirmed, holding (1) the evidence was sufficient for the jury to find Defendant guilty of kidnapping as a Class Y felony, and therefore, the circuit court did not err in denying Appellant's motion for a directed verdict; and (2) the trial court did not abuse its discretion in admitting the testimony at the sentencing phase of the trial. View "Huff v. State" on Justia Law

A jury convicted Appellant of rape and sentenced him to life in prison without the possibility of parole. On appeal, Appellant argued that the trial judge erred by allowing the introduction of a prior offense into evidence under Ark. R. of Evid. 404(b). Appellant's principal point on appeal was that the pedophile exception was inapplicable to his prior conviction because the two offenses were factually dissimilar and temporally improximate and because there was no evidence he had an intimate relationship with either victim. The Supreme Court affirmed, holding that the trial judge did not abuse his discretion in finding that Appellant's prior conviction satisfied the pedophile exception to Rule 404(b), as (1) there were sufficient similarities between the two cases, (2) there was sufficient evidence of intimate relationships; and (3) because Appellant committed both offenses as an adult and assaulted each child victim in the same manner, the trial judge's decision to admit Appellant's relatively old conviction was reasonable. View "Craigg v. State" on Justia Law

In 2009, judgment was entered reflecting that Petitioner had been found guilty of multiple felony offenses. He was sentenced as a habitual offender to an aggregate term of 504 months' imprisonment. The court of appeals affirmed. The court of appeals' mandate was issued on June 2, 2010. On January 20, 2012, more than eighteen months after the mandate was issued, Petitioner filed a pro se petition for postconviction relief. The trial court denied the petition on the ground that it was untimely filed. The Supreme Court dismissed Petitioner's appeal and declared the motion related to the appeal moot, holding that the trial court did not err in denying the petition because it was untimely filed. View "Bates v. State" on Justia Law

Petitioner entered a negotiated plea of guilty to a charge of first-degree murder and was sentenced to 360 months' incarceration. Six years later, Petitioner filed a pro se petition for writ of error coram nobis, which the circuit court denied. Petitioner did not timely file a notice of appeal. Petitioner subsequently filed a pro se motion to belatedly lodge an appeal from the circuit court's order. The Supreme Court denied the petition, as Petitioner did not preserve his right to appeal the postconviction order or meet his burden of demonstrating that there was good cause for his failure to perfect his appeal in a timely manner. View "Meadows v. State" on Justia Law

Appellant appealed the decree entered by the circuit court granting the petition of Appellees, Appellant's parents, to adopt Appellant's daughter. On appeal, Appellant contended that the circuit court erred in denying her request for the appointment of counsel because, as an indigent, she was entitled to appointed counsel in a private adoption proceeding under both the federal and state Constitutions. She also argued that the circuit court's findings in support of the adoption were clearly erroneous. The Supreme Court affirmed, holding (1) Appellant's first argument was not preserved for appeal; (2) the circuit court correctly found that Appellant's consent to the adoption was not necessary; and (3) the circuit court's finding that the adoption was in the child's best interest was not clearly erroneous. View "Lucas v. Jones" on Justia Law

Appellant was convicted of capital murder and attempted capital murder and sentenced to consecutive sentences of life in prison without parole, thirty years' imprisonment, and a fifteen-year enhancement for using a firearm during the commission of the attempted capital murder. Appellant appealed his convictions and sentences based on alleged error committed by the circuit court in admitting three of his text messages into evidence. The Supreme Court affirmed, holding (1) Appellant failed to preserve his Stores Communications Act argument and his illegal-search argument based on the Arkansas Constitution for the Court's review; and (2) because there was sufficient evidence to authenticate all three text messages at issue, the circuit court did not abuse its discretion in admitting any of the three text messages at trial. View "Gulley v. State" on Justia Law