Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of rape, three counts of first-degree sexual assault, and two counts of sexual indecency with a child and sentencing him to two terms of life imprisonment, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the circuit court abused its discretion by admitting testimony of a certain witness under the pedophile exception to Ark. R. Evid. 404(b). The Supreme Court affirmed, holding (1) Defendant's first argument was not preserved for appellate review; (2) Defendant's argument that the circuit court erred in denying his motion for a mistrial was not preserved; and (3) the circuit court did not err in excluding evidence of the victims' prior sexual conduct pursuant to the rape-shield statute set forth in Ark. Code Ann. 16-42-101(c). View "Wilder v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and his sentence to life in prison, holding that substantial evidence supported the conviction.After a jury trial, Defendant was convicted of the murder of his ex-wife and sentenced to life imprisonment. As his sole point on appeal, Defendant argued that there was insufficient evidence supporting his conviction, and therefore, the trial court erred in denying his motion for a directed verdict. The Supreme Court disagreed and affirmed, holding that there was substantial evidence to support Defendant's capital murder conviction, and there was no error with respect to the jury's rejection of Defendant's affirmative defense argument. View "Wofford v. State" on Justia Law

The Supreme Court reversed the ruling of the circuit court finding that the emergency clause contained within Act 237 of 2023 (the LEARNS Act) did not receive a separate roll-call vote as required under the Arkansas Constitution, rendering the clause procedurally invalid, holding that Arkansas General Assembly complied with Ark. Const. V, 1 when it enacted the LEARNS Act emergency clause.After the General Assembly passed the LEARNS Act the legislation was sent the Governor, who signed it into law. Appellees brought the underlying complaint seeking a declaration that the Act's emergency clause, under which certain provisions became effective on the date of the Governor's approval, was invalid. Upon remand, the circuit court declared the LEARNS Act emergency clause invalid because it did not receive a separate roll-call vote. The Supreme Court reversed, holding that the emergency clause was passed in compliance with article 5, section 1. View "Ark. Dep't of Education v. Jackson" on Justia Law

The Supreme Court denied a petition for writ of certiorari and/or prohibition requesting relief from the Court after the circuit court denied Petitioner's motions to dismiss the charges against him, holding that an extraordinary writ was not necessary in this case.Petitioner, who was charged with aggravated robbery and other charges, moved to dismiss the charges for a violation of his right to a speedy trial pursuant to Ark. R. Crim. P. 28.1, asserting that he was not brought to trial within twelve months from the date of his arrest. Petitioner also filed a motion to dismiss for lack of jurisdiction, alleging that the juvenile division retained exclusive jurisdiction. The circuit court denied both motions. The Supreme Court denied Petitioner's ensuing petition for writ of certiorari and/or prohibition, holding that the circuit court did not err in denying Petitioner's motions to dismiss for lack of jurisdiction and for violation of his speedy-trial rights. View "Tilson v. State" on Justia Law

The Supreme Court reversed the order of the circuit court granting a temporary restraining order (TRO) in favor of Plaintiffs in their lawsuit challenging the validity of the emergency clause in Act 237 of 2023 (the LEARNS Act), holding that the circuit court erred in granting Plaintiffs' motion for injunctive relief.After the LEARNS Act was signed into law Plaintiffs sought a TRO, asserting that they would suffer irreparable harm if Defendants continued to implement the Act despite an invalid emergency clause relating to the creation of transformation contracts. The circuit court granted the TRO until a scheduled hearing. The Supreme Court reversed and vacated the TRO, holding that Plaintiffs failed to meet their burden of providing irreparable harm. View "Ark. Dep't of Education v. Jackson" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder and sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the trial court's failure to instruct the jury with the model verdict form on dispute accomplice status was reversible error under the third and fourth exceptions enumerated in Wicks v. State, 606 S.W.2d 366 (Ark. 1980). The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress evidence obtained during a search of his property; and (2) neither Wicks exception to the objection requirement applied under the circumstances of this case. View "Nowell v. State" on Justia Law

In this case presenting four questions of law concerning the constitutionality of Act 1108 of 2021, which amended section 18-50-116 of the Arkansas Statutory Foreclosure Act, the Supreme Court held that Act 1108 cannot apply retroactively to a mortgagor whose claim has vested and declined to answer the remaining certified questions.At issue before the Supreme Court was whether Act 1108 was unconstitutional (1) because it applies retroactively; (2) because the term “substantially comply” in section 2(d)(2)(D) is void for vagueness; (3) because it deletes Section 2(d)(2)(C)(ii); or (4) for any other reason the Court may find. The Supreme Court held that Act 1108 cannot apply retroactively to mortgagors with pending claims and declined answer the remainder of the certified question because the answer would not be dispositive of any issue between the parties. View "Alpe v. Federal Nat'l Mortgage Ass'n" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Appellant of first-degree murder and other crimes and sentencing him to an aggregate term of two life sentences plus 835 years' imprisonment, holding that the State failed to demonstrate that Appellant was brought to trial within the twelve-month period required by Ark. R. Crim. P. 28.1(b).At issue on appeal was whether Appellant's constitutional right to a speedy trial, as embodied in Ark. R. Crim. P. 28.1, was violated when the State failed to bring him to trial within twelve months of the date of his arrest. The Supreme Court concluded that Appellant's right was indeed violated because he was held for a total of 405 days during which the speedy trial was not tolled, a total that exceeded the requisite 365-day period. View "Parker v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting summary judgment in favor of Plaintiffs on their illegal-exaction claim related to Amendment 101 to the Arkansas Constitution, holding that the circuit court erred in its interpretation of Amendment 101.Plaintiffs brought this action against State Defendants raising claims related to tax revenue from both Amendment 91 and Amendment 101. The circuit court granted summary judgment in favor of State Defendants on the Amendment 91 illegal-exaction claim and in favor of Plaintiffs on their Amendment 101 claim. The Supreme Court reversed the circuit court's ruling pertaining to Amendment 101, holding that the circuit court erred in its interpretation of Amendment 101 to the Arkansas Constitution. View "Gibson v. Little Rock Downtown Neighborhood Ass'n" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order dismissing Appellant's appeal from the district court absent a conviction as required by Ark. R. Crim. P. 36(a), holding that the district court illegally imposed court costs and probation in violation of Appellant's state and federal constitutional due process rights and his federal and state constitutional right to a trial.Appellant pled guilty to carrying a weapon in a publicly owned building. The district court ordered Appellant to pay court costs of $140 and told Appellant if there were no further charges within thirty days the charge would be dismissed. The court dismissed the case at the end of thirty days for lack of jurisdiction on the grounds that there was no underlying conviction. The Supreme Court reversed in part, holding that the court had jurisdiction to hear Appellant's challenge to the legality of his de facto sentence, and Appellant should have been heard on the merits. View "Gillette v. City of Fort Smith" on Justia Law