Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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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

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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

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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

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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

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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

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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

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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

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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

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The Supreme Court affirmed the judgment of the circuit court dismissing without prejudice Appellants' claims against Appellees, the Board of Trustees of the University of Arkansas System and others, holding that the circuit court did not err by determining that Appellants lacked standing and that their claims were unripe and nonjusticiable.Appellants, tenured factual members employed by the University of Arkansas System, filed on behalf of themselves and all others similarly situated a complaint against the Board seeking declaratory and injunctive relief based on alleged violations of both federal and state law. The Board filed a motion to dismiss, arguing that claims should be dismissed based on lack of standing, unripeness, and failure to state a claim. The circuit court granted the motion. The Supreme Court affirmed, holding that the circuit court correctly dismissed Appellants' claims. View "Palade v. Board of Trustees" on Justia Law

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The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law