Justia Arkansas Supreme Court Opinion Summaries

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

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

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

The Supreme Court affirmed Appellant's conviction of capital murder, holding that the evidence was sufficient to sustain the conviction and that the circuit court did not err in denying Appellant's motion to suppress tracking data generated by his cellphone.On appeal, Appellant argued that the trial court erred by denying his directed-verdict motion because the evidence supported the defense's theory of the case that he did not intend to shoot the victim. Further, Appellant argued that the court abused its discretion in denying his motion to suppress evidence obtained from the seizure of AT&T phone records. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the capital murder conviction; and (2) the circuit court correctly denied the motion to suppress. View "Thomas v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition.Appellant was found guilty of two counts of delivery of a controlled substance and one count of maintaining a drug premises. In his habeas petition, Appellant argued that he was actually innocent because his arrest and conviction was based on the false testimony of a witness who had a lengthy criminal history. Appellant further argued that the writ should issue because he was not afforded effective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims regarding the witness's credibility do not constitute a valid assertion that he was being unlawfully detained; and (2) Appellant did not actually connect an allegation of ineffective assistance of counsel to his allegation that he was unlawfully detained. View "Cave v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for mistrial, holding that the circuit court's decision to admit into evidence a translation of a letter Defendant wrote in Spanish did not violate Ark. R. Evid. 1009 or Defendant's Sixth Amendment right to confrontation.Defendant was convicted of rape. On appeal, the Supreme Court held (1) there was no reversible error as a result of the bailiff's response to the jury foreman's question regarding the verdict forms, which resulted in the foreman mistakenly signing the forms for both rape and attempted rape, as shown by polling the members of the jury individually; and (2) Defendant did not have a constitutional right to confrontation because the translated statements were attributable to Defendant and, therefore, nontestimonial, and the accompanying affidavit to the letter substantially complied with Rule 1009. View "Garcia-Chicol v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had the capacity to knowingly and intelligently waive his postconviction remedies, including his Ark. R. Crim. P. 37.5 petition, was not clearly erroneous and affirmed the circuit court's dismissal of Defendant's Rule 37.5 petition, holding that the court did not err.Defendant was convicted was capital murder and other crimes. Defendant later filed for postconviction relief pursuant to Ark. R. Crim. P. 37.5, arguing that counsel was constitutionally ineffective for failing to investigate sufficiently whether he was intellectually disabled. Counsel subsequently advised the circuit court that Defendant desired to waive his postconviction remedies, including his Rule 37.5 petition, which counsel asked the court to dismiss. After a hearing to determine whether Defendant had the capacity to waive his postconviction remedies, the circuit court concluded that Defendant's waiver was made knowingly and intelligently. The Supreme Court affirmed, holding that the circuit court did not err in dismissing Defendant's Rule 37.5 petition. View "Lard v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's illegal exaction suit against the City of Blytheville and its Sewer Department (collectively, the City), holding that the circuit court properly granted summary judgment.In her complaint, Plaintiff claimed that a $5 fee for sewer system repairs and upgrades, imposed pursuant to a city ordinance, was a tax and constituted an illegal exaction in violation of article 16, section 13 of the Arkansas Constitution. The circuit court granted the City's motion for summary judgment and dismissed all of Plaintiff's claims with prejudice. The Supreme Court affirmed, holding that the circuit court correctly found that the fee was not a tax and, therefore, not an illegal exaction. View "Watson v. City of Blytheville" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5, holding that there was no error in the circuit court's order denying Rule 37 relief.Defendant was convicted of capital murder and sentenced to death. Numerous proceedings followed. This appeal concerned Defendant's petition for postconviction relief. The circuit court entered an order denying Defendant relief on every claim. The Supreme Court affirmed, holding (1) there was no deficient performance by trial counsel under the Strickland standard; (2) the circuit court did not err in denying relief on the issue of Defendant's competency to stand trial; (3) Defendant's claim of juror misconduct was not cognizable in this postconviction proceeding; and (4) Defendant's remaining claims did not warrant reversal of his convictions. View "Roberts v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no basis for the writ.Appellant pleaded guilty to capital murder, attempted capital murder, and unlawful discharge of a firearm. Appellant later filed his petition for writ of habeas corpus, arguing that the State lacked jurisdiction to try him for the offenses because they were referred to as "international terrorism" committed by a "foreign terrorist organization" and that he was not afforded effective assistance of counsel. The Supreme Court affirmed, holding (1) the fact that Appellant's conduct could have been charged as a crime under a federal statute did not prohibit the State from trying him in state court; and (2) Appellant's claims of ineffective assistance of counsel were not cognizable as a ground for the writ. View "Muhammad v. State" on Justia Law