Justia Arkansas Supreme Court Opinion Summaries

Gloria Daniel was fired from her position as a registered nurse at the Arkansas State Hospital thirteen months after she reported to Charles Smith, the hospital’s administrator, that a patient’s death was attributable to abuse or neglect on the part of the hospital. Daniel filed suit, asserting claims under the Arkansas Whistle-Blower Act, the Arkansas Civil Rights Act, and federal law, naming as Defendants Smith in his individual and official capacities, and Betty Mains in her official and individual capacities as the hospital’s assistant administrator. The circuit court concluded that Daniel’s claim for retaliation was not barred by sovereign immunity and that Defendants were not entitled to qualified immunity. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) did not err in denying Defendants’ motion for summary judgment based on sovereign immunity; and (2) erred in denying Defendants’ motion for summary judgment to dismiss the individual-capacity claims based on qualified statutory immunity grounds. View "Smith v. Daniel" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Appellant later filed a pro se petition for writ of habeas corpus, claiming actual innocence, challenging the sufficiency of the evidence to support his conviction, and alleging that the circuit court lacked subject-matter jurisdiction to retry his case because of a speedy-trial violation. The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish a basis for a finding that a writ of habeas corpus should issue. View "Hubbard v. Hobbs" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment, plus fifteen years for a firearm enhancement. The Supreme Court affirmed the convictions and sentence, holding (1) there was substantial evidence to support Appellant’s conviction for first-degree murder, and the circuit court did not err in denying Appellant’s motion for directed verdict; (2) the circuit court did not err in denying Appellant’s motion to suppress his statements; and (3) the circuit court did not err in denying Appellant’s motion in limine to exclude certain photographs that Appellant claimed were irrelevant and more prejudicial than probative.` View "Airsman v. State" on Justia Law

In 1998, Appellant pleaded guilty to multiple felony offenses and was sentenced to an aggregate term of life imprisonment without parole. Thereafter, Appellant filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, which was denied. In 2010, Appellant filed in the trial court a petition for writ of error coram nobis, arguing that he was denied effective assistance of counsel when he entered his guilty plea and during his Rule 37.1 proceeding. The trial court denied the petition. Now before the Supreme Court were Appellant’s pro se motion for extension of time to file his brief-in-chief and his petition for writ of certiorari in which he urged the Court to find that the trial court erred in denying his petition for writ of error coram nobis. The Supreme Court dismissed the appeal and declared the motion and petition moot, holding that Appellant failed to establish a sufficient ground for issuance of the writ. View "Millsap v. State" on Justia Law

Deer/Mt. Judea School District (“Deer/Mt. Judea”) filed a complaint on its own behalf and on behalf of its students and taxpayers, alleging that the State had illegally and unconstitutionally failed to provide adequate funding to small, remote schools, some of which it closed. Deer/Mt. Judea sought declarations that the State’s school-funding and education systems were inequitable and inadequate and that section 32 of Act 293 of 2010 constituted special legislation and injunctions prohibiting the closure of the small, remote schools, among other things. The Supreme Court reversed the circuit court’s dismissal of some of Deer/Mt. Judea’s claims. Fort Smith School District, Greenwood School District, Alma School District, and Van Buren School District (collectively, “Fort Smith”) filed a motion to intervene in the litigation. The circuit court denied the motion, concluding that Fort Smith’s motion was untimely, and even if it was timely, Fort Smith did not have an interest in the case that needed to be protected. The Supreme Court affirmed the denial of the motion to intervene, holding that the circuit court did not abuse its discretion in denying the motion for intervention as untimely. View "Fort Smith Sch. Dist. v. Deer-Mt. Judea Sch. Dist." on Justia Law

Appellant entered a negotiated plea of guilty in one case to fleeing on foot and possession of methamphetamine and to residential burglary and robbery in another case. Appellant subsequently filed a pro se petition and amended petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 that encompassed both cases, claiming that his counsel provided ineffective assistance when he entered his plea to the four offenses. The trial court denied postconviction relief. The Supreme Court affirmed the denial of postconviction relief, holding that the claims raised by Appellant in his postconviction motion and argued on appeal were without merit. View "Sherman v. State" on Justia Law

After a jury trial, Appellant was found guilty of two counts of raping his seven-year-old stepdaughter. After the mandate issued, Appellant filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 alleging, among other claims, ineffective assistance of counsel. The trial court dismissed the petition after a hearing. The Supreme Court affirmed, holding (1) the trial court did not clearly err in holding that counsel’s performance was not ineffective; (2) the trial court correctly held that Appellant’s claim of prosecutorial misconduct at trial was not cognizable in a Rule 37.1 proceeding; and (3) Appellant’s claim that he was dissatisfied with his attorney’s representation in the Rule 37.1 proceeding was not grounds to reverse the trial court’s order and remand for a new hearing. View "McNichols v. State" on Justia Law

Appellant, an inmate of the Arkansas Department of Correction, was found guilty of capital murder in the stabbing death of a fellow inmate. Appellant filed a pro se petition for writ of habeas corpus, arguing that the trial court made several errors in its rulings on defense motions during voir dire and during trial and that his counsel provided ineffective assistance. The circuit court dismissed the petition, noting that the action counted as a “strike” pursuant to Ark. Code Ann. 16-68-607. The Supreme Court affirmed, holding (1) Appellant did not show that the court failed to address any issue cognizable in a habeas proceeding; (2) Appellant’s claims of trial error and ineffective assistance of counsel were not within the purview of a habeas proceeding; and (3) inasmuch as Appellant’s petition for writ of habeas corpus failed to state a claim on which relief was merited, the circuit court did not err in declaring that the petition constituted a strike under the statute. View "Tucker v. Hobbs" on Justia Law

Shelley Kane, a resident of Texas, filed for emergency temporary guardianship of T.S., her minor niece, citing the declining health of Lois Swenson, the adoptive mother of T.S. The circuit court appointed Kane as temporary guardian. Thereafter, Swenson challenged the constitutionality of Ark. Code Ann. 28-65-203(f)(1), alleging that it creates a procedural law regarding service. In the meantime, Kane filed for permanent guardianship of T.S. After a final hearing, the circuit court appointed Kane as permanent guardian of T.S. and declared section 28-65-203 constitutional because its provisions are “special proceedings” pursuant to Ark. R. Civ. P. 81. The Supreme Court affirmed, holding that Kane’s appointed guardianship was a special proceeding and excepted from the Rules of Civil Procedure and governed by statute. View "Swenson v. Kane" on Justia Law

Defendant was charged with drug and firearm offenses. Defendant filed a motion to suppress the items discovered during a search of his person and his minivan. The circuit court granted the motion after a hearing. The State appealed, arguing that the circuit court erred as a matter of law (1) by concluding that additional officer testimony was required to support the pat down of Defendant, and (2) when it found that a warrant was required to search a locked safe discovered in Defendant’s minivan. The Supreme Court dismissed the appeal in part and reversed and remanded in part, holding (1) the State’s first point on appeal is not appealable because it involves the circuit court’s consideration of the particular facts of the case and its determination that those facts did not justify the search of Defendant’s person; and (2) the circuit court erred as a matter of law in finding that, absent exigent circumstances, a warrant was required to search the safe in Defendant’s minivan. View "State v. Crane" on Justia Law