Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition for a writ of error coram nobis, which mooted Appellant's motion to file a belated brief-in-chief, holding that it was clear from the record that Appellant's allegations failed state a claim for coram nobis relief.In his petition, Appellant asserted that his guilty plea was not voluntarily or intelligently entered because his counsel led him to believe that his sentence would be life imprisonment, not life imprisonment without the possibility of parole. The Supreme Court dismissed the appeal, holding that Appellant did not allege that his guilty plea resulted from any form of physical or psychological duress as required for a writ of error coram nobis in this context. View "Wade v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to reinvest jurisdiction in the trial court so that he may proceed with a petition for writ of error coram nobis in his criminal case, holding that error coram nobis was not available to address Petitioner's claims.In his petition, Petitioner argued that the writ should issue because there were flaws in his trial and in his direct appeal, including trial error, prosecutorial misconduct, due process violations, and ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner did not allege grounds for the writ because none of his claims were based upon information outside of the record or otherwise unknown to Petitioner. View "Williams v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court terminating Mother's parental rights to her son, holding that the circuit court did not commit reversible error by denying Mother's counsel's motion to withdraw.The Arkansas Department of Human Services opposed the motion to withdraw, arguing that Mother had been served under Ark. R. Civ. P. 5 and that she had over a month to fire her attorney and hire a new one. The circuit court denied the motion. On appeal, Mother argued that, by denying the motion, the circuit court violated her Sixth Amendment right to counsel of one's choosing. The Supreme Court affirmed, holding that the denial of the motion to withdraw was not an issue preserved on appeal and that, even if this Court were to consider the merits of Mother's constitutional claims, her argument would still fail. View "Langston v. Arkansas Department of Human Services" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's petition for postconvicton relief pursuant to Ark. R. Crim. P. 37, holding that the performance of Appellant's trial counsel was not deficient, and therefore, the circuit court's denial of Appellant's Rule 37 petition was not clearly erroneous.Appellant was convicted of one count of first-degree battery and one count of second-degree battery. After Appellant's convictions and sentences were affirmed on direct appeal, Appellant filed a petition for postconviction relief alleging that his trial counsel was ineffective in failing to investigate and call certain witnesses. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden under the first prong of Strickland v. Washington, 466 U.S. 668 (1984), because he did not demonstrate that his trial counsel's performance fell below an objective standard of reasonableness. View "Hinton v. State" on Justia Law

The Supreme Court affirmed the circuit court's award of attorney's fees to Plaintiff in his illegal-exaction lawsuit successfully challenging the constitutionality of certain legislative acts but remanded for further proceedings, holding that attorney's fees were permitted and that the matter should be remanded to the circuit court with instructions to consider the factors set forth in Chrisco v. Sun Industries, Inc., 800 S.W.2d 717 (Ark. 1990), in determining whether the amount of fees requested by Plaintiff was reasonable under the circumstances.The circuit court awarded attorney's fees to Plaintiff in the amount of $323,266 based on Plaintiff's illegal-exaction suit alleging that certain legislative acts of 2015 appropriating funds from the Arkansas General Improvement Fund (GIF) to eight regional planning and developmental districts were unconstitutional. The amount was one-third of the remaining GIF funds involved. The Supreme Court held (1) sovereign immunity was not an issue in this case; (2) attorney's fees were permitted in this case; and (3) because the circuit court did not make any findings with respect to what a reasonable attorney's fee would be in this case, the case must be remanded for reconsideration of the amount of attorney's fees. View "Walther v. Wilson" on Justia Law

The Supreme Court reversed Appellant’s conviction for first-degree murder, for which she was sentenced to life imprisonment, holding that the trial court violated Appellant’s fundamental right to a public trial by closing the courtroom to the public during the testimony of a State witness.For her first point on appeal, Appellant argued that the closure of the courtroom during the testimony of the State witness violated her constitutional right to a public trial. At issue on appeal was whether the test set forth in Waller v. Georgia, 467 U.S. 39, 48 (1984), for determining when the right of an accused to a public trial may give way to other rights or interests was met. The Supreme Court held that the trial court did not make the findings necessary to support the closure, and therefore, the case must be remanded for a new trial. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant’s petition for postconviction relief pursuant to Ark. R. Crim. P. 37, holding that the circuit court did not err in summarily denying Appellant’s claim that his trial counsel was ineffective and that appellate counsel was not ineffective.Specifically, the Supreme Court held (1) contrary to Appellant’s argument on appeal, Appellant’s trial counsel did not provide ineffective assistance when he compared Appellant’s case to the O.J. Simpson case; and (2) appellate counsel was not ineffective by failing to challenge the sufficiency of the evidence on direct appeal. View "Woods v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant’s petition for postconviction relief filed under Ark. R. Crim. P. 37, holding that the circuit court’s decision to deny the petition was not clearly erroneous.Appellant was convicted of first-degree murder and possession of a firearm and was sentenced to a term of life imprisonment. Appellant’s convictions and sentences were affirmed. Appellant later filed a petition for postconviction relief under Rule 37, arguing, among other things, that his trial counsel was ineffective for failing to present proper jury instructions on extreme-emotional-disturbance manslaughter. On remand, the circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant was not entitled to a jury instruction on extreme emotional disturbance, and therefore, Appellant was not entitled to postconviction relief. View "Douglas v. State" on Justia Law

The Supreme Court reversed the decision of the circuit court and dismissed this matter in its entirety, holding that the circuit court exceeded its jurisdiction on remand, and therefore, its actions following remand were void.The Supreme Court decided a previous appeal in this case brought by Appellants seeking to join the enforcement of an ordinance passed by the City of Fayetteville. On appeal, the Court held that the circuit court erred in finding that the ordinance did not violate Act 137 of 2015, Ark. Code Ann. 14-1-401 to -403. At the time the case was remanded, the only claim before the circuit court was Appellants’ request for a declaratory judgment and injunction. On remand, however, the circuit court allowed certain parties to intervene and raise a new claim regarding the constitutionality of Act 137. The Supreme Court reversed the circuit court’s order denying a preliminary injunction, holding that the circuit court exceeded its jurisdiction on remand, and because the sole issue over which the circuit court properly had jurisdiction was conclusively decided by the Supreme Court in its previous opinion, the Court dismissed the matter in its entirety. View "Protect Fayetteville v. City of Fayetteville" on Justia Law

In this interlocutory appeal concerning legislative and executive privilege in Arkansas the Supreme Court held that the legislative and executive privileges exist in Arkansas.At issue in this case was whether Ordinance 5781, passed by the City of Fayetteville following the passage of Act 137, conflicted with Act 137. The Supreme Court held that Fayetteville’s ordinance conflicted with Act 137 and could not stand. On remand, the State moved to quash subpoenas of two state legislators and for a discovery order barring discovery requests for the production of documents held by the legislative and executive branches. The circuit court denied the State’s motions. The State appealed. The Supreme Court reversed and remanded, holding (1) this case was moot but the mootness exception applies; (2) the Speech and Debate Clause affords legislators privilege form certain discovery and testimony, and the privilege extends beyond statements and acts made on the literal floor of the House; and (3) the executive privilege also exists in Arkansas. View "Protect Fayetteville v. City of Fayetteville" on Justia Law