Justia Arkansas Supreme Court Opinion Summaries

Plaintiffs-taxpayers were indebted to the state for delinquent tax debts. The Department of Finance & Administration filed certificates of indebtness against Plaintiffs with respect to the tax delinquencies and assessed interest on Plaintiffs prior to and after the filing of certificates of indebtedness. Plaintiffs filed a complaint for declaratory and injunctive relief against Defendant, in his official capacity as Director of the Department, alleging illegal-exaction claims and due-process violations. Defendant moved to dismiss the complaint pursuant to Ark. R. Civ. P. 12(b)(1) and (6), alleging that Appellants had failed to plead facts necessary to establish subject-matter jurisdiction and failed to plead facts on which relief may be granted. The circuit court dismissed with prejudice Appellants’ complaint. The Supreme Court affirmed, holding that the circuit court did not err in (1) dismissing Appellants’ illegal-exaction claims where Appellants did not claim that the underlying tax delinquency was illegal; and (2) ruling that Appellants failed to plead facts to support their due-process-violation claims. View "Sanford v. Walther" on Justia Law

Game wardens conducted an investigation into Appellant’s compliance with hunting laws. After the investigation was completed, the officers began a criminal investigation seeking information to determine whether Appellant was a felon. Upon discovering that he was a felon, the officers arrested and searched Appellant. Appellant filed a motion to suppress, arguing that he was unlawfully detained and unlawfully searched because the game wardens had neither a warrant nor a reasonable suspicion of any violation of law. The circuit court denied the motion. The Supreme Court agreed with Appellant and reversed, holding that, under the circumstances of this case, the officers did not have reasonable suspicion to conduct a criminal investigation. Remanded. View "Pickle v. State" on Justia Law

After a jury trial in 1995, Appellee was convicted of capital murder and sentenced to a mandatory life sentence without the possibility of parole. In 2013, Appellee filed a petition for writ of habeas corpus asserting that his sentence to life imprisonment was illegal pursuant to Miller v. Alabama because he was a juvenile at the time of the offense. The circuit court granted Appellee’s petition, vacated and set aside his offense, and reinvested the circuit court that convicted Appellee with jurisdiction to conduct resentencing proceedings. The Supreme Court reversed and remanded, holding that the circuit court had not followed the procedures mandated by the habeas-corpus statutes. On remand, the circuit court held a hearing and ruled that Appellee was entitled to relief. The Supreme Court affirmed, holding (1) the circuit court did not err by concluding that Miller applies retroactively; and (2) the circuit court’s ruling regarding equal protection and due process was not in error. View "Kelley v. Gordon" on Justia Law

After a jury trial, Appellant was found guilty of possession of drug paraphernalia with intent to manufacture methamphetamine and possession of drug paraphernalia. Appellant was sentenced to a total of 144 months’ imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief under Ark. R. Crim. P. 37, alleging ineffective assistance of counsel. The circuit court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) trial counsel erred by failing to object to the prosecutor’s statement that the jury had not “heard both sides yet” but, even assuming that the statement was improper, Appellant failed to show that she was prejudiced by the statement; and (2) the Court declined to overrule previous decisions refusing to apply the cumulative-error doctrine to claims of ineffective assistance of counsel. View "Houghton v. State" on Justia Law

Defendant was charged with the first-degree murder of John Davis. The jury found Defendant guilty of the lesser-included offense of second-degree murder. The court of appeals affurned, concluding that substantial evidence supported the jury’s finding that Defendant acted with the purpose to seriously injure Davis. Defendant subsequently filed a verified, pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. The trial court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Defendant received effective assistance of counsel; and (2) Defendant’s remaining arguments were not cognizable under Rule 37.1. View "Hooks v. State" on Justia Law

The State charged Defendant with one count of arson. Defendant filed a motion to suppress evidence seized in a warrantless search of Defendant's burned building that was conducted three days after the fire during an insurance company investigation. Defendant asserted that law enforcement officers did not have probable cause to search the building without a search warrant, and therefore, the search was invalid. The circuit court granted Defendant’s motion to suppress, finding that certain evidence and photographs taken from the burned premises during the warrantless search violated the Fourth Amendment. The State brought this interlocutory appeal. The Supreme Court dismissed the appeal, as the appeal did not involve the interpretation of the law or the uniform administration of justice, as required by Ark. R. App. P.-Crim. 3(c). View "State v. Brashers" on Justia Law

After a jury trial, Appellant was found guilty of murder in the second degree and being a felon in possession of a firearm. Appellant was sentenced as a habitual offender to a term of imprisonment and a fine. The court of appeals affirmed. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, arguing that he was denied the effective assistance of counsel in several respects. Appellant's petition was denied. The Supreme Court affirmed, holding that Appellant failed to meet his burden of establishing that he was denied effective assistance of counsel under the standard set forth in Washington v. Strickland. View "Stalnaker v. State" on Justia Law

Appellant was the owner of gas, oil, and other minerals situated within the Ozark Highlands Unit (OHU). SEECO, Inc. applied to create a drilling unit in the OHU and to integrate all unleased and uncommitted mineral interests within the unit. The Arkansas Oil and Gas Commission established the unit and integrated all unleased and uncommitted mineral interests within the unit with the exception of Appellant’s unleaded mineral interests. At a hearing before the Commission to hear evidence related to SEECO’s request to integrate Appellant’s unleaded mineral interests into the drilling unit, Appellant asserted that the Commission’s forced-integration procedures amounted to a taking of his property. The Commission subsequently integrated Appellant’s unleaded mineral interests into the drilling unit. The circuit court affirmed the Commission’s decision. The Supreme Court affirmed, holding (1) the forced integration procedures do not amount to an unconstitutional taking; and (2) the Commission’s order did not deprive Appellant of his constitutional right to a jury trial to determine just compensation for his property. View "Gawenis v. Ark. Oil & Gas Comm'n" on Justia Law

After a jury trial, Petitioner was convicted of capital murder, residential burglary, attempted capital murder, rape, and aggravated robbery. Petitioner was sentenced to death for the capital murder conviction. The Supreme Court affirmed Petitioner’s convictions and sentences. Petitioner sought postconviction relief under Ark. R. Crim. P. 37.1, and the Supreme Court affirmed the circuit court’s denial of the petition. Petitioner now petitioned the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, arguing that the prosecution withheld material evidence in violation of Brady v. Maryland. The Supreme Court granted the petition to reinvest jurisdiction, holding that the State withheld evidence that might have led counsel to utilize a defense based on an alternate suspect. View "Isom v. State" on Justia Law

Appellant entered a conditional plea of no contest to one count of misdemeanor possession of a firearm by certain persons. Appellant appealed, arguing that the circuit court erred in denying his motion to dismiss because (1) he had not been adjudicated mentally ill or involuntarily committed to a mental institution in violation of Ark. Code Ann. 5-73-103(a), and (2) section 5-73-103(a)(3) is void for vagueness, violates Appellant's due process under the federal Constitution, and violates the Second Amendment to the federal Constitution and article 2, section 5 of the state Constitution. The Supreme Court dismissed in part and affirmed in part, as (1) Appellant’s first point was not properly before the Court; and (2) Appellant’s remaining points were not raised below and ruled upon by the circuit court. View "Gooch v. State" on Justia Law