Justia Arkansas Supreme Court Opinion Summaries

Appellant Bobby Hatton was found guilty of first-degree terroristic threatening and second-degree domestic battery in the presence of a child. The trial court subsequently found that Appellant had violated the conditions of his probations in two other cases by committing the offenses of which he had been convicted in the first case and revoked both probations. Appeals in all three cases were consolidated. The court of appeals affirmed the judgment in the first case and revocation orders in the other two cases. Appellant subsequently filed a pro se petition for postconviction relief that encompassed all three cases. The trial court denied the petition. Before the Supreme Court were two motions filed by Appellant related to the appeal. The Court dismissed the appeal and declared the motions moot, holding that because Appellant's petition was not in compliance with Ark. R. Crim. P. 37.1, it did not act to confer jurisdiction on the trial court to consider the merits of the petition, and therefore, the Court lacked jurisdiction to consider the appeal. View "Hatton v. State" on Justia Law

Appellant was found guilty of underage driving under the influence. Appellant subsequently appealed the denial of his motion to suppress the results of his breathalyzer test, arguing that the arresting officer was acting outside of his territorial jurisdiction when he transported Appellant to a different county to perform the breathalyzer test and that the test results were thus unlawfully obtained. The Supreme Court affirmed the denial of the motion to suppress after citing with approval the reasoning employed by the Rhode Island Supreme Court in State v. Hagan, holding that the officer's actions in the present case were both reasonable and lawful, and therefore, the circuit court did not err in denying the motion. View "Pickering v. State" on Justia Law

Appellant Michael MacKool was convicted of first-degree murder and theft of property, for which a cumulative sentence of sixty years' imprisonment in the Arkansas Department of Correction (ADC) was imposed. The Supreme Court affirmed. The State subsequently filed a petition pursuant to the State Prison Inmate Care and Custody Reimbursement Act seeking reimbursement from Appellant's inmate account of a portion of the cost of housing Appellant in the ADC. After a hearing, the circuit court determined that the State was entitled to the $5016 in Appellant's inmate account, and a written order was entered that ordered deposit of that money into the state treasury. Appellant timely appealed. Before the Supreme Court was Appellant's motion to file his reply brief belatedly. The Court (1) denied the motion, as Appellant's tendered reply brief did not comply with the Court's rules; and (2) affirmed the circuit court's decision to order reimbursement from Appellant's inmate account. View "MacKool v. State" on Justia Law

Appellant Brian Jordan appealed an order of the circuit court convicting him of rape and sentencing him as a habitual offender to life imprisonment. The Supreme Court affirmed, holding (1) the circuit court did not err in allowing prior offenses into evidence, as the court properly found the prior convictions were more probative than prejudicial and thus admissible pursuant to Ark. R. Evid. 609; and (2) Appellant's argument that he was entitled to a new trial based upon the circuit court's comments to the jury just prior to the court's dismissal of the jury was not preserved for appeal, as Appellant did not object at the time to the statements made to the jury. View "Jordan v. State" on Justia Law

Petitioner was charged by an information with having committed three felony drug-related counts. Petitioner subsequently filed four pro se pleadings in those proceedings. Later, Petitioner filed a petition for writ of mandamus, seeking an order from the Supreme Court directing the circuit judge in his case to issue an order disposing of the pro se pleadings. The Court concluded that Petitioner simply wished some disposition of the pleadings and, more specifically, requested that a written order be entered on the record addressing the merits of his arguments concerning the court's assumption of jurisdiction in the criminal proceeding so he could seek interlocutory review. The Supreme Court denied the petition, as (1) Petitioner did not provide a record that demonstrated that issuance of the writ was appropriate; and (2) Petitioner did not establish that the trial court did not adequately dispose of the pleadings on the record or that the trial court had a duty to enter a written order that addressed the merits of his jurisdictional challenge. View "Brown v. Circuit Court (Gibson) " on Justia Law

Appellant Jeremiah Walton was convicted of two counts of rape and received an aggregate sentence of 300 months' imprisonment. Appellant subsequently filed a petition for postconviction relief and, on the same day, motions that sought a copy of the transcript, appointment of counsel, and leave to proceed in forma pauperis. The court granted Appellant's motion to proceed as an indigent but denied the request for counsel and the request for a copy of the transcript. The trial court later denied Appellant's petition. The Supreme Court affirmed, holding (1) the trial court did not err in denying the requests Appellant made concerning his preparations for the hearing on the petition; and (2) the trial court did not err in failing to rule on each of the claims in the petition. View "Walton v. State" on Justia Law

Appellant N.D. was a juvenile when he was adjudicated delinquent for commission of aggravated robbery and possession of a weapon. After N.D. escaped from the detention center, the State filed a felony information charging N.D. as an adult with capital murder, escape in the first degree, aggravated robbery, theft of property, and second-degree battery. After the Supreme Court reversed the criminal court's denial of N.D.'s motion to transfer his case to the juvenile court, the criminal court transferred N.D.'s case to juvenile court. The juvenile court subsequently entered a decision that N.D. be designated for extended juvenile jurisdiction (EJJ). N.D. appealed, asserting that the criminal court already declined to make such a designation, and because the Supreme Court did not reverse that refusal in N.D.'s first appeal, the issue was decided by law of the case. The Supreme Court affirmed, holding that the Court did not previously reach a decision or provide direction to the criminal court with respect to EJJ designation, nor did the criminal court make a decision regarding EJJ designation, and so the law-of-the case doctrine did not bar the juvenile court from granting the State's motion for an EJJ designation. View "N.D. v. State" on Justia Law

Appellant Frank Garner was found guilty by a jury of kidnapping and rape. Appellant subsequently filed in the circuit court in which he was convicted a petition for writ of habeas corpus. The circuit court denied the petition after finding that Appellant had failed to rebut the presumption against timeliness. Appellant appealed and filed a motion for extension of time in which to file his brief-in-chief. The Supreme Court dismissed the appeal and declared the motion moot, holding that the circuit court's denial of Appellant's original petition for writ of habeas corpus based on Apellant's failure to rebut the presumption against timeliness was not clearly erroneous. View "Garner v. State" on Justia Law

This FOIA action stemmed from requests made by Appellant after she was stopped for speeding by a police officer. Appellant filed a complaint alleging (1) the police department (Department)'s refusal to provide the requested records violated the FOIA, (2) asserting that the Department's requirement that she pay $2,475 for copying of the records was not permitted under the FOIA, and (3) alleging that the Department engaged in spoliation of evidence in an attempt to circumvent the FOIA. The circuit court dismissed Appellant's complaint after finding the Department did not violate the FOIA. The Supreme Court affirmed in part and reversed in part, holding that the circuit court (1) erred in finding there was no FOIA violation by the Department with regard to Appellant's first FOIA request; (2) erred in concluding that the Department's requirement of a fee in the amount of $2,475 was reasonable and not a violation of the FOIA; and (3) did not err in finding the Department did not violate the FOIA in purging the records pursuant to its forty-five-day policy. View "Daugherty v. Jacksonville Police Dep't" on Justia Law

The court of appeals reversed and remanded Petitioner David Anderson's original conviction for first-degree murder. Following a new trial on the same charge, Petitioner was again convicted, and he received a life sentence. The Supreme Court affirmed. Petitioner subsequently filed a petition asking that the Supreme Court reinvest jurisdiction in the trial court and permit him to file a petition for writ of error coram nobis. Petitioner then filed a motion for addition, a motion seeking to amend the petition, six amendments, and motions to voluntarily dismiss, to compel, and to raise objections. The Supreme Court (1) granted the motion that sought to amend the petition; (2) denied the motions to dismiss and compel; and (3) denied the petition with its amendments, holding that none of the claims raised in Petitioner's petition or amendments had merit. View "Anderson v. State" on Justia Law