Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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In 2009, Central Arkansas Water, which owns and operates Lake Maumelle as a public water supply, authorized the collection of a “watershed fee” imposed on wholesale customers, including Appellants. That same year, Pulaski County and Central Arkansas Water (collectively, Appellees) entered into a watershed protection agreement. Appellants filed suit on behalf of themselves and other similarly situated taxpayers, arguing that the watershed fee constituted an illegal exaction and that the the watershed protection agreement necessitated Central Arkansas Water to expend public funds illegally. The circuit court entered summary judgment for Appellees, concluding that the agreement was a proper contract for administrative services. The Supreme Court affirmed, holding that the circuit court correctly ruled that the watershed protection agreement was a valid agreement under Arkansas law. View "Sullins v. Cent. Ark. Water" on Justia Law

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In 2012, Appellant was found guilty of rape and sexual indecency with a minor. An aggregate sentence of 480 months’ imprisonment was imposed. The Supreme Court affirmed. In 2014, Appellant filed a pro se petition for writ of habeas corpus, contending that he was not afforded effective assistance of trial counsel and that the evidence was insufficient to sustain the judgment of conviction. The circuit court denied relief, and Appellant appealed. The Supreme Court dismissed the appeal and declared moot the motion filed in connection to the appeal, holding that Appellant failed to state a basis on which the writ could issue. View "Pruitt v. State" on Justia Law

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After a jury trial, Appellant was convicted of rape and tampering with physical evidence. The Supreme Court affirmed on all points except for the tampering with physical evidence conviction, which the Court reversed and dismissed, holding (1) Appellant’s arguments that the circuit court erred in denying his directed-verdict motions on the rape conviction were not preserved for appellate review; (2) substantial evidence did not support Appellant’s conviction for tampering with physical evidence; (3) Appellant waived his right to pursue his argument that the circuit court erred when it failed to remove a juror with ties to the rape victim’s family; and (4) the circuit court did not abuse its discretion when it declined Appellant’s request to give a lesser-included offense jury instruction for the rape charge. View "Hartman v. State" on Justia Law

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After a jury trial, Appellant was found guilty of three counts of aggravated robbery and one count of theft of property. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Appellant’s convictions because the State introduced ample direct and circumstantial evidence that Appellant was the person who committed the crimes; (2) the circuit court did not err in allowing the State to introduce into evidence certain audio recordings of phone conversations; and (3) the Court was precluded from reviewing either of Appellant’s assertions of ineffective assistance of counsel. View "Chatmon v. State" on Justia Law

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In 1979, Appellant pleaded guilty to attempted murder and was sentenced to life imprisonment. Appellant was seventeen years old when he committed the offense. In 2011, Appellant filed a pro se complaint for declaratory relief alleging that the parole-eligibility statute was unconstitutional as applied to him because Graham v. Florida established that the Eighth Amendment prohibits the imposition of life imprisonment without parole for juvenile offenders convicted of nonhomicide offenses. The circuit court denied the complaint. Appellant appealed. The Supreme Court ordered Appellant to file a supplemental addendum, as Appellant’s addendum was deficient in that he failed to provide certain pleadings pursuant to Ark. R. Sup. Ct. 4-7. View "Bramlett v. Hobbs" on Justia Law

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In 2009, Appellant was convicted of rape, sexual indecency with a child, and possessing matter depicting sexually explicit conduct involving a child. The Arkansas Department of Correction (ADC) applied Ark. Code Ann. 16-93-611 to Appellant’s sentence for the crime of rape to determine his parole-eligibility date. The court of appeals affirmed. In 2013, Appellant filed a pro se petition for declaratory judgment and for writ of mandamus against the Director of the ADC, arguing that the application of section 16-93-611(a)(1) to his sentence was an unconstitutional sentence enhancement and that he was denied due process of law by the application of the statute without notice. The circuit court dismissed the petition. The Supreme Court affirmed, holding that because the arguments raised by Appellant in this appeal primarily stemmed from his erroneous characterization of section 16-93-611 as an enhancement statute, none of the claims for relief in Appellant’s petition demonstrated that he was entitled to any relief by means of a declaratory judgment or a writ of mandamus. View "Mason v. Hobbs" on Justia Law

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In 2013, Defendant was convicted of three counts of rape, three counts of aggravated robbery, and one count of Class B felony kidnapping. Defendant’s convictions arose from three separate incidents that occurred in January, 2001. Defendant appealed, arguing that the abolition by Ark. Code Ann. 5-1-109(b)(1)(B) and (j) of the statute of limitations defense for defendants whose DNA profile is included in a DNA database violates the Equal Protection Clause. The Supreme Court affirmed, holding that the statutory provisions eliminating the statutes of limitation for DNA-identified defendants do not violate Defendant’s right to equal protection. View "Brown v. State" on Justia Law

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After a jury trial, Appellant was found guilty of murder. The Supreme Court affirmed. Appellant then filed a petition for postconviction relief, alleging ineffective assistance of counsel. The trial court denied the petition after conducting an evidentiary hearing. Appellant appealed the denial of his postconviction petition. The Supreme Court affirmed, holding (1) there was no error in the adequacy of the order issued by the trial court in support of its findings dismissing Appellant’s petition; and (2) the trial court did not err in finding that Defendant received constitutionally effective assistance of counsel. View "Anderson v. State" on Justia Law

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After a jury trial in 1989, Appellant was found guilty of murder in the first degree and sentenced as a habitual offender to 200 years’ imprisonment. In 2000, Appellant filed a pro se petition for writ of habeas corpus alleging that the 200-year sentence exceeded the statutory maximum sentence for first-degree murder and was thus illegal. The Supreme Court denied the petition, holding that the sentence was within statutory range. In 2014, Appellant filed a pro se petition for writ of habeas corpus, raising seven claims. The circuit court denied the petition. the Supreme Court affirmed, holding (1) Appellant’s claim that his sentence was excessive had already been addressed; and (2) the remaining allegations raised by Appellant were not cognizable in a habeas proceeding. View "Scott v. State" on Justia Law

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After a jury trial, Appellant was found guilty of sexual indecency with a child and sexual assault in the second degree. After the conviction was affirmed on appeal, Appellant filed a petition for postconviction relief, alleging, among other things, that his counsel provided ineffective assistance. The trial court dismissed the petition, concluding that it was untimely filed. This appeal concerned Appellant’s third pro se petition for postconviction relief in which he made essentially the same allegations as he raised in his first postconviction petition. The trial court denied and dismissed the petition, ruling that Appellant could not file a subsequent petition for postconviction relief when a postconviction petition alleging essentially the same claims had already been denied as being untimely. The Supreme Court affirmed, holding that because Appellant did not appeal from the order dismissing his first petition as untimely, his third petition was likewise untimely, and the trial court had no jurisdiction to grant the relief sought. View "Newton v. State" on Justia Law