Justia Arkansas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the order of the circuit court denying Appellant's complaint for declaratory judgment and injunctive relief and petition for writ of mandamus seeking to direct Appellees to allow Appellant to carry a firearm inside the district court, holding that there was no error.Appellant, an attorney, filed a complaint for declaratory judgment and injunctive relief seeking a declaration that Act 1087 of 2017, codified at Ark. Code Ann. 5-73-122(b), authorizes attorneys as "officers of the court" to carry a firearm in any of the state's courts or courthouses and a declaration that Appellees' conduct in refusing to allow Appellant to enter the Pulaski County District Courthouse with a firearm violated Arkansas law. Appellant further sought mandamus relief asking that the court direct Defendants to permit attorneys in court with a firearm. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's mandamus petition. View "Corbitt v. Pulaski County Jail" on Justia Law

The Supreme Court affirmed the order of the circuit court entering judgment upon a jury verdict finding Defendant guilty of rape and sentencing him to life in prison, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the State intentionally circumvented his right to confront vital witnesses by improperly allowing into evidence a surreptitious recording made by Defendant's roommate and that the recording contained inadmissible hearsay. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the rape conviction; and (2) the circuit court did not err in admitting the recording into evidence. View "Wallace v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for writ of habeas corpus, holding that Petitioner's statutory and constitutional claims did not raise jurisdictional issues that entitled him to habeas relief.Petitioner was convicted of capital murder and first-degree battery and sentenced to a life sentence plus consecutive twenty-four sentences. The Supreme Court affirmed on direct appeal. Petitioner later brought this petition alleging that he was not named in the body of the criminal information and that he was not identified in the document, and therefore, the trial court lacked jurisdiction over him. The circuit court denied the habeas corpus petition. The Supreme Court affirmed, holding that the trial court had personal and subject-matter jurisdiction over Petitioner. View "Lee v. Payne" on Justia Law

The Supreme Court vacated the order of the circuit court declaring Act 1002 of 2021 to be unconstitutional and permanently enjoining its enforcement, holding that the circuit court did not have subject matter jurisdiction to enter the order.The Act, codified at Ark. Code Ann. 20-7-144, prohibited state agencies, political subdivisions of the state, and local and state officials from mandating the use of face masks, face shields, or other face coverings. Two lawsuits were filed seeking to declare the Act unconstitutional and enjoin its enforcement. The circuit court consolidated the cases, enjoined enforcement of the Act, and preliminary declared the Act unconstitutional in violation of the separation of powers and equal protection clauses of the state Constitution. The Supreme Court vacated the order below, holding that the circuit court lacked jurisdiction to enter the final order because an interlocutory appeal was still pending. View "State v. McClane" on Justia Law

The Supreme Court affirmed the order of the trial court denying and dismissing Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentences were illegal.After a jury trial, Appellant was convicted of second-degree murder and sentenced as a habitual offender to eighty years' imprisonment. In his petition to correct an illegal sentence, Appellant asserted that the application of Ark. Code Ann. 5-4-501(c) to enhance his sentence was illegal and that the enhanced sentence violated the prohibition against the ex post facto application of criminal statutes. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his enhanced sentence was an illegal sentence pursuant to section 16-90-111. View "Rainer v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for two counts of first-degree murder and other crimes and his sentence of consecutive terms of life in prison for each murder, holding that Defendant was not entitled to relief on his claims of error.On appeal, Defendant argued that the testimony of surviving victim Lajhonta Collier identifying Defendant as the perpetrator was erroneously admitted and that the State presented insufficient evidence to support the convictions. The Supreme Court affirmed, holding (1) substantial evidence supported the jury's verdict; and (2) the circuit court did not clearly err in determining that Defendant's pretrial identification was not constitutionally improper. View "Wilson v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's Rule 37 petition alleging ineffective assistance of counsel during his criminal trial, holding that there was no error or abuse of discretion.Defendant was convicted of and sentenced to death for capital murder. The Supreme Court affirmed. Defendant later filed a petition for postconviction relief arguing that his trial counsel were constitutionally ineffective for multiple reasons. The circuit court denied the petition. The Supreme Court affirmed, holding that Defendant's allegations of error were unavailing. View "Holland v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law