Justia Arkansas Supreme Court Opinion Summaries

Duane Gonder, an inmate serving a lengthy prison sentence following guilty pleas to multiple charges in 2010, filed a petition for declaratory and injunctive relief against the Arkansas Attorney General. He challenged the constitutionality of Arkansas Code Annotated section 5-54-119(a), which criminalizes furnishing prohibited articles in correctional facilities. Gonder contended that the statute, as interpreted in Laster v. State, 76 Ark. App. 324, 64 S.W.3d 800 (2002), was unconstitutional as applied to him and other inmates who never leave the prison facility, arguing that it violated due process and equal protection. He asserted that he and similarly situated inmates faced a threat of prosecution for actions that, under his reading of the statute, should not apply to them.The Pulaski County Circuit Court, Third Division, dismissed Gonder’s petition without prejudice. The circuit court found that Gonder lacked standing and failed to present a justiciable controversy, and imposed a strike under applicable Arkansas law. The court reasoned that Gonder’s claims were speculative and hypothetical, rather than based on a present injury or sufficient facts to establish an actual controversy. Gonder appealed this decision.The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s dismissal. The court held that Gonder had not alleged sufficient facts demonstrating standing, as he did not show a present injury or a concrete threat of prosecution under the challenged statute. The court further agreed that no justiciable controversy existed, as Gonder’s claims were speculative and not ripe for judicial determination. As a result, the dismissal without prejudice became a dismissal with prejudice, and Gonder’s motion for a decision based on his brief alone was rendered moot. The imposition of a strike was also affirmed. View "GONDER v. GRIFFIN" on Justia Law

John Mercer was charged with two counts of driving while intoxicated (DWI) in Garland County, Arkansas, in 2017. He pled no contest to both charges in 2018. The Garland County District Court imposed fines, required alcohol education, and placed Mercer on at least six months of probation, which included a $25 monthly probation fee and conditions such as random drug and alcohol testing. Mercer made several probation-fee payments as a result. Mercer later filed a lawsuit, alleging that probation and associated fees in DWI cases are not authorized under Arkansas law and therefore constitute an illegal exaction. He also asserted federal and state due-process claims, seeking declaratory and injunctive relief and repayment of the fees collected.The Garland County District Court moved to dismiss Mercer’s complaint in the Garland County Circuit Court, arguing that it was entitled to sovereign immunity under the Arkansas Constitution. The circuit court denied the motion to dismiss, rejecting the sovereign immunity defense. After further proceedings and amended complaints, the district court again sought dismissal, but the circuit court denied the motion. The district court then filed an interlocutory appeal to the Supreme Court of Arkansas, challenging the denial of sovereign immunity.The Supreme Court of Arkansas held that Mercer’s illegal-exaction claim may proceed because the Arkansas Constitution expressly authorizes such claims, overriding sovereign immunity. The court also held that Mercer’s federal due-process claim survives dismissal, as state sovereign immunity cannot categorically bar federal causes of action in state courts of general jurisdiction. However, the court ruled that Mercer’s Arkansas Civil Rights Act claim is barred by sovereign immunity, as there is no constitutional authorization for such suits against the state. The court affirmed the circuit court’s order in part, reversed it in part, and remanded the case for further proceedings. View "GARLAND COUNTY DISTRICT COURT v. MERCER" on Justia Law

A substitute teacher employed by a staffing agency regularly worked in a school district where her child was a student. After a dispute arose between her and her child’s teacher, she filed an ethics complaint regarding the teacher’s conduct with the Arkansas Department of Education. Subsequently, the school district informed the staffing agency that she should not substitute at the school during the investigation, and later extended this prohibition to all district schools. She was still able to work at other schools in the county contracted with the agency. The state ultimately found her complaint baseless.She filed suit alleging that the district and two administrators retaliated against her in violation of federal and state law, including the Rehabilitation Act, 42 U.S.C. § 1983, and the Arkansas Civil Rights Act. The Saline County Circuit Court granted her partial summary judgment, finding liability on her claims, and the jury awarded compensatory and punitive damages. The court also issued a permanent injunction preventing the district from barring her employment as a substitute.The Supreme Court of Arkansas reviewed the case and held that her Rehabilitation Act claim failed because she was not an employee of the district, as required for such claims. For her § 1983 and Arkansas Civil Rights Act claims, the court found she had not established liability against the district or the administrators. Specifically, she did not show that the district acted under an official policy or custom, nor did her speech constitute a matter of public concern protected by the Constitution in the context of a government contractor relationship. The court also vacated the permanent injunction, as no substantive claim survived.The Supreme Court of Arkansas reversed the circuit court’s summary judgment rulings, the jury’s damages award, and the order granting a permanent injunction, and remanded for entry of judgment in favor of the appellants. View "BENTON SCHOOL DISTRICT v. GREER" on Justia Law

Following the discovery of Van Stevens’s brutal murder in Searcy, Arkansas, police identified Christopher Coy Gamble as a suspect based on his proximity to the crime and evidence tying him to the victim’s residence. Gamble, who was on parole at the time, was observed near the crime scene and was linked to incriminating items found at a neighbor’s property, including belongings previously returned to him by police. Surveillance footage, eyewitness accounts, and a custodial statement in which Gamble admitted being in the victim’s home further implicated him, although Gamble denied committing the murder.The White County Circuit Court conducted a jury trial, during which Gamble moved to suppress his custodial statement, arguing it resulted from a pretextual arrest, and sought to strike the venire after a potential juror expressed an opinion of his guilt. The circuit court denied both motions, finding no grounds for suppression or for striking the jury panel, and a jury subsequently convicted Gamble of capital murder and aggravated residential burglary, resulting in life and sixty-year sentences, respectively.The Supreme Court of Arkansas reviewed the case. On appeal, Gamble challenged the denial of his suppression motion, relying on State v. Sullivan, which barred pretextual arrests under the Arkansas Constitution. The Supreme Court of Arkansas overruled Sullivan, holding that Arkansas’s constitutional standard mirrors the federal “reasonableness” test: an arrest is lawful if supported by probable cause, regardless of the officer’s subjective motivation. The court concluded Gamble’s arrest was proper because he possessed drug paraphernalia in the officer’s presence. The court also found no abuse of discretion in denying Gamble’s motion to strike the venire, as the circuit court’s admonition sufficiently cured any potential prejudice. The Supreme Court of Arkansas affirmed Gamble’s convictions. View "GAMBLE v. STATE OF ARKANSAS" on Justia Law

In July 2011, Roschell Lamb reported to police that she had been raped by a stranger who dragged her into a shed and assaulted her. The police investigation initially yielded no suspects, and the case went dormant until 2018, when Roy Nichols was identified as a suspect through DNA evidence. After locating Lamb in 2023, the State charged Nichols with rape. Nichols claims the encounter was consensual and seeks to introduce evidence that he and Lamb had a prior sexual relationship, specifically alleging they had sex weeks before the incident.The Craighead County Circuit Court held an in camera hearing regarding Nichols’s motion to introduce evidence of the alleged prior sexual encounter. Nichols testified about the supposed prior relationship, and his mother and sister claimed Lamb had visited their home looking for Nichols around the time of the alleged rape. The circuit court found Nichols’s testimony about prior consensual sexual conduct probative of consent and allowed him to testify about it and cross-examine Lamb on the topic, but excluded testimony from Nichols’s mother and sister. The State appealed this evidentiary ruling.The Supreme Court of Arkansas reviewed the circuit court’s decision for abuse of discretion. It concluded the circuit court erred because Nichols’s claim was uncorroborated, only marginally probative, and highly prejudicial. The Court held that Arkansas’s rape-shield statute generally prohibits introduction of evidence of prior sexual conduct unless it is acutely probative and corroborated. The Court also found that Nichols’s Confrontation Clause argument was unavailing, as he could challenge Lamb’s credibility through other means. The Supreme Court of Arkansas reversed the circuit court’s ruling and remanded the case for proceedings consistent with its opinion. View "STATE OF ARKANSAS v. NICHOLS" on Justia Law

A candidate for the Arkansas House of Representatives was challenged by his opponent, who argued that she was ineligible to run for office due to a prior disposition in a 2018 hot-check case. The challenger claimed that the opponent had been found guilty of violating the Arkansas Hot Check Law, which, under state constitutional and statutory provisions, would render her ineligible for election. The evidence included a district court docket showing a disposition labeled “GUILTY – BOND FORFEITURE,” as well as payment of fines, fees, and restitution related to the charge. The opponent did not contest the existence of the underlying case but denied that she had been convicted or found guilty.The case was first heard in the Pulaski County Circuit Court. After a hearing that included testimony from court and law enforcement personnel about the court’s procedures, and review of the district court records, the circuit court concluded that the bond forfeiture was not an admission of guilt. The court found that the opponent had neither entered a plea nor been found guilty by the court. The circuit court therefore held that she had not been convicted of an infamous crime or a public trust crime under Arkansas law, and denied the challenger’s petition for declaratory judgment and mandamus.On appeal, the Supreme Court of Arkansas reviewed the record and the circuit court’s findings under a clearly erroneous standard. The Supreme Court affirmed the lower court’s decision, holding that a bond forfeiture, without a plea or factual finding of guilt, does not constitute a conviction or render a candidate ineligible under Article 5, Section 9 of the Arkansas Constitution or the relevant statutes. The Supreme Court rejected the challenger’s remaining arguments and affirmed the circuit court’s judgment. View "DAY V. WARDLAW" on Justia Law

The appellant was convicted by a jury of raping the 14-year-old daughter of his then-live-in girlfriend. The evidence included testimony that he sent the victim sexually explicit messages, gave her alcohol, and raped her while she was intoxicated. Several years later, after the appellant described to the victim’s mother in a series of electronic messages how he had raped his own daughters, the mother reported the abuse. Further testimony was provided by one of the appellant’s daughters, who described a longstanding pattern of sexual abuse and grooming by the appellant. The appellant was sentenced to life in prison.Prior to this appeal, the Garland County Circuit Court presided over the trial. The appellant moved for a continuance after being charged in a separate case with raping another of his daughters, arguing that the new charges impaired his ability to participate in his defense. The circuit court denied the motion, finding the appellant was able to assist his counsel. The court also overruled the appellant’s objections to the admission of explicit electronic messages and testimony from his daughter describing other uncharged sexual offenses, concluding that authentication and evidentiary standards were met. The jury convicted the appellant and imposed a life sentence.On review, the Supreme Court of Arkansas addressed the appellant’s challenges to both his conviction and sentence. The court held that substantial evidence supported the jury’s finding that the appellant was in a position of authority over the victim as required by Arkansas law. The court found no abuse of discretion in the denial of the continuance or in the admission of the challenged evidence, holding that the evidence was properly authenticated and the testimony of the appellant’s daughter was admissible under the “pedophile exception” to Arkansas Rule of Evidence 404(b). The court further held that the life sentence did not violate the Eighth Amendment or the Arkansas Constitution. The judgment was affirmed. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

In this case, two licensed medical marijuana businesses in Arkansas challenged the validity of twenty-eight legislative amendments made by the Arkansas General Assembly to Amendment 98 of the Arkansas Constitution, which established a framework for medical marijuana use in the state. The businesses argued that these amendments were unconstitutional because they had not been submitted for voter approval, as they claimed was required, and that the amendments were not germane to the pertinent section as required by the constitutional language.The Pulaski County Circuit Court agreed with the plaintiffs, relying on the precedent set by Arkansas Game & Fish Commission v. Edgmon, and ruled that the General Assembly lacked authority to amend a voter-initiated constitutional amendment without submitting those amendments to a public vote. The court also found that the legislative amendments were not germane to section 23 of Amendment 98 and were therefore unconstitutional and void. The State of Arkansas appealed this ruling.The Supreme Court of Arkansas reviewed the case and reversed the circuit court’s decision. The court held that Article 5, section 1 of the Arkansas Constitution does grant the General Assembly authority to amend voter-initiated laws, including initiated constitutional amendments, by a two-thirds vote of both legislative chambers. The court explicitly overruled Arkansas Game & Fish Commission v. Edgmon, finding its reasoning inconsistent with the plain constitutional text. Additionally, the court determined that the word “section” in section 23(a) of Amendment 98 should be interpreted as “amendment,” so the germaneness requirement applies to the amendment as a whole. Consequently, the Supreme Court of Arkansas reversed and dismissed the lower court’s ruling. View "STATE OF ARKANSAS v. GOOD DAY FARM ARKANSAS, LLC" on Justia Law

James Ray Davis pleaded guilty in 2017 to several charges, including commercial and residential burglary. Later, while incarcerated, Davis filed a pro se petition for writ of habeas corpus in the county of his incarceration. In his petition, Davis asserted that his guilty plea was induced by prosecutor deception, ineffective assistance of counsel, and trial court misconduct. He also alleged constitutional and due process violations. The petition included affidavits that were difficult to interpret, and although Davis used a form referencing Arkansas Code Annotated section 16-112-201, he did not claim actual innocence or request scientific testing.The Jackson County Circuit Court treated Davis’s petition as seeking habeas relief under sections 16-112-101 to -123, since he neither stated a claim under section 16-112-201 nor filed the petition in the county of conviction as required for claims based on new scientific evidence. The circuit court denied Davis’s petition, concluding that he failed to state a cognizable action for the writ to issue. Specifically, the court found that Davis did not provide a sentencing order showing the alleged illegality of his sentence and did not demonstrate either facial invalidity of the judgment or lack of circuit court jurisdiction.The Supreme Court of Arkansas reviewed the case and applied the clearly erroneous standard to the circuit court’s ruling. The court held that Davis failed to establish a basis for habeas relief because he did not show that the judgment was invalid on its face or that the circuit court lacked jurisdiction. Without the sentencing order or proof of illegality, the Supreme Court of Arkansas affirmed the circuit court’s denial of Davis’s petition. View "DAVIS v. STATE OF ARKANSAS" on Justia Law

A citizen of Cleburne County submitted a petition for a local ballot initiative, titled the “Hand Marked, Hand Counted Paper Ballot Ordinance of 2024,” to the county clerk for inclusion in the 2024 general election. The county clerk rejected the petition, determining that there were insufficient valid signatures because some paid canvassers were not Arkansas residents as required by law. The canvassers later submitted supplemental affidavits listing Arkansas addresses, but the clerk still refused to count those signatures.The petitioner then filed suit in the Cleburne County Circuit Court, seeking a writ of mandamus and an injunction to compel the clerk to count the disputed signatures and certify the petition if it met the signature requirements. After an expedited hearing, the circuit court granted both the writ and the injunction, ordering the clerk to count all signatures, including those “cured” by the supplemental affidavits, and to certify the petition if it was sufficient.On appeal, the Supreme Court of Arkansas reviewed whether the circuit court could require the county clerk to certify a local ballot initiative that was not timely filed under the Arkansas Constitution. The Supreme Court held that Article 5, section 1 of the Arkansas Constitution sets the exclusive timeline for filing local initiative petitions—no sooner than ninety days and no later than sixty days before the election. The petition in question was filed too early for the 2024 election and, by operation of statute, would have been certified for the 2026 election, but it was also untimely for that election under the constitutional timeline. The Supreme Court held that the relevant statutory provisions were unconstitutional to the extent they conflicted with the constitutional timeline. The court reversed the circuit court’s order and dismissed the case, holding that a circuit court cannot require certification of an untimely initiative. View "EVANS v. HARRISON" on Justia Law