Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not determining that Appellant failed to state grounds demonstrating probable cause that he was being illegally detained. In his petition, Appellant argued that the general principle in Miller v. Alabama, 567 U.S. 460 (2012) that mandatory life-without-parole sentences should not apply to juveniles under the age of eighteen should apply to him because he was still young and immature. The circuit court denied relief, finding that Miller has not be applied to extend relief to offenders over the age of eighteen. The Supreme Court affirmed, holding (1) the circuit court properly denied Appellant's petition for writ of habeas corpus; and (2) Appellant did not establish that he was entitled to a hearing. View "Benton v. Kelley" on Justia Law

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The Supreme Court affirmed Defendant's conviction for various drug and drug-related offenses and sentencing him to an aggregate term of forty years' imprisonment, holding that the trial court did not abuse its discretion in admitting evidence of the presence of filmmakers at the search of Defendant's residence. When DEA officers and other law enforcement officers executed a warrant for the search of Defendant's home, they found drugs and drug paraphernalia. An HBO documentary film crew was present at the search under an agreement with law enforcement. The filmmakers did not participate in the search, nor did they include footage of the search in a documentary that later aired on HBO. On appeal from his convictions, Defendant argued, among other things, that the trial court abused its discretion by refusing to order the State to obtain the HBO video footage of the search of Defendant's home and to identify the filmmakers who were present. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in declining to order the State to obtain the video; (2) did not abuse its discretion in denying Defendant's request for a continuance; (3) did not abuse its discretion in granting the State's motion to exclude testimony about the film; and (4) erred in giving a nonmodel instruction, but the error was harmless. View "Harmon v. State" on Justia Law

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In this action challenging the decision of the Arkansas Medical Marijuana Commission disqualifying Carpenter Farms Medical Group, LLC's application for a marijuana-cultivation facility the Supreme Court affirmed in part and reversed and dismissed in part the judgment of the circuit court denying the State's motion to dismiss based on sovereign immunity, holding that the complaint may go forward only under Ark. Code Ann. 25-15-207 and the declaratory judgment action alleging an equal protection violation. In its complaint, Carpenter Farms asserted (1) it was the only 100 percent minority-owned applicant and that the Commission singled out its application for disparate treatment in violation of equal protection guarantees; and (2) the Commission violated the Administrative Procedure Act by failing to adopt certain rules and improperly applying the rules it did adopt. The circuit court denied the State's motion to dismiss based on sovereign immunity. The Supreme Court reversed and dismissed in part, holding (1) the lawsuit cannot proceed regarding the Commission's application of its own rules or as an administrative appeal; and (2) Carpenter Farms can go forward with it claim that the Commission failed to adopt model rules and with its declaratory judgment action alleging an equal protection violation. View "Arkansas Department of Finance & Administration v. Carpenter Farms Medical Group, LLC" on Justia Law

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In this appeal returning to the Supreme Court for a third time challenging an award of attorney's fees to Plaintiff in his illegal exaction lawsuit that successfully challenged the constitutionality of certain legislative acts (Acts), the Supreme Court held that the circuit court properly awarded attorney's fees. In his illegal exaction complaint Plaintiff alleged that the challenged Acts were unconstitutional. The trial court ultimately granted judgment in favor of Plaintiff. The parties then began sparring over attorney's fees. The circuit court eventually awarded attorney's fees but denied Plaintiff's request for prejudgment interest. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in awarding $323,266 in attorney's fees and did not err when it denied Plaintiff prejudgment interest. View "Walther v. Wilson" on Justia Law

Posted in: Constitutional Law
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The Supreme Court reversed the ruling of the circuit court denying the motion filed by Asa Hutchinson, the Governor of the State of Arkansas, to dismiss an action filed by Appellee, an inmate in the Arkansas Department of Correction, holding that the complaint was barred by sovereign immunity. Appellee filed a complaint challenging the constitutionality of the Fair Sentencing of Minors Act of 2017 (FSMA), codified at Ark. Code Ann. 16-93-621, alleging that the FSMA denied him equal protection and due process of law, subjected him to cruel and unusual punishments, and violated the Americans with Disabilities Act. The circuit court dismissed the action with respect to all defendants except Hutchinson in his official capacity. The Supreme Court reversed, holding that the circuit court erred in ruling that Appellee pleaded sufficient facts to overcome Hutchinson's defense of sovereign immunity. View "Hutchison v. Mcarty" on Justia Law

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The Supreme Court denied Petitioner's motion asking the Court to proceed with a belated appeal of a judgment reflecting his conviction on drug-related charges, holding that the trial court did not err in finding that Petitioner waived his right to appeal and that trial counsel had performed within an objectively reasonable standard. As grounds for the motion, Petitioner asserted that he asked counsel to appeal. The matter was remanded for a hearing. The trial court ultimately concluded that Petitioner waived his right to appeal and that counsel acted within an objective standard of reasonableness in not pursuing an appeal. The Supreme Court affirmed, holding that the trial court's conclusions were supported by the transcript and were not clearly erroneous. View "Smith v. State" on Justia Law

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The Supreme Court affirmed the decision of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the performance of Appellant's trial counsel was not deficient. Appellant was convicted of capital murder and sentenced to death. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5 alleging, among other claims, that trial counsel was ineffective concerning the mitigating circumstances presented to the jury and the failure to call any witnesses but his sister at the sentencing phase. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant's claim that he received ineffective assistance of counsel during the sentencing phase. View "Johnson v. State" on Justia Law

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The Supreme Court denied Petitioner's second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and second petition for writ of certiorari, holding that Petitioner was not entitled to either coram nobis relief or issuance of a writ of certiorari. In two separate trials, Petitioner was convicted of the rapes of two girls and the rape of a five-year-old child and burglary. Petitioner subsequently filed multiple petitions for psostconviction relief, including the instant petitions for coram nobis relief and seeking issuance of a writ of certiorari. The Supreme Court denied coram nobis relief, holding (1) the claims raised in Petitioner's second coram nobis petition that reasserted claims raised in Petitioner's first coram nobis petition were an abuse of the writ; and (2) the remaining claims were either outside the scope on which the writ may issue or did not establish that Petitioner was entitled to coram nobis relief. The Court also denied Petitioner's petition for writ of certiorari, holding that the arguments in the petition could have been raised at trial or on direct appeal. The Court further denied Petitioner's motion for appointment of counsel as unwarranted and motion to withdraw as moot. View "Lukach v. State" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Appellant's claims for postconviction relief raised under Ark. R. Crim. P. 37.1, holding that none of counsel's alleged errors created a reasonable probability of a different outcome had they not occurred. In denying postconviction relief, the trial court held that the alleged deficient actions of trial counsel were based on reasonable strategic and legal grounds and that counsel's alleged errors would not have changed the outcome of the trial. The Supreme Court affirmed, holding that to the extent trial counsel's performance arguably satisfied the first prong of Strickland, the failure did not satisfy the second prong - that Appellant's counsel's error was sufficiently prejudicial as to show a reasonable probability of a different outcome. View "Reynolds v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Appellant's action against Baptist Health appellees and John Hearnsberger, M.D., holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of disputed discovery. Appellant, a surgeon, was on the medical staff of Baptist Health from 2003 until 2011, when his appointment and clinic privileges at Baptist Health Medical Center-Little Rock were terminated, effective immediately. Baptist Health also reported the suspension of Appellant's clinical privileges to the Arkansas State Medical Board, which, in 2014, revoked Appellant's license. Appellant appealed the revocation, and his license was reinstated. In 2011, Appellant filed a lawsuit against Baptist Health and several individuals, asserting several claims. The circuit court entered a consent order dismissing the Medical Board and Dr. Hearnsberger in his official capacity. The circuit court then granted summary judgment on Appellant's remaining claims. The Supreme Court reversed in part, holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of discovery, and the discovery error was not harmless as to Appellant's discrimination and tortious-interference claims. View "Williams v. Baptist Health" on Justia Law