Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Smith v. State
The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder, kidnapping, aggravated robbery, and theft of property but remanded for the circuit court to correct the sentencing order, holding that there was no reversible error.Specifically, the Supreme Court held (1) the circuit court did not err in denying Appellant's motion for directed verdict on the capital-murder, kidnapping, and aggravated-robbery charges; (2) the circuit court did not abuse its discretion in denying Defendant's motion to suppress; (3) due to a discrepancy between the sentencing order and the pronouncement of sentence, this matter must be remanded for the court to correct the order; (4) the circuit court did not abuse its discretion in admitting three exhibits over Appellant's hearsay objections; (5) the circuit court did not abuse its discretion by allowing the State to question Appellant about three prior bad acts; and (6) Appellant was not entitled to relief on his remaining claims of error. View "Smith v. State" on Justia Law
Bentonville School District v. Sitton
The Supreme Court reversed the order of the circuit court enjoining the enforcement of the Bentonville School District's mask policy in favor of Plaintiffs, parents of school children, holding that the the circuit court abused its discretion in granting Plaintiffs' motion for a temporary restraining order (TRO).In granting the TRO, the circuit court concluded that the school policy at issue violated Plaintiffs' right under Ark. Const. art. II, 21 and 29 to care for their children and that the District lacked the authority to issue the mask policy. The Supreme Court reversed, holding that (1) the circuit court abused its discretion in finding that the policy violated Plaintiffs' constitutional rights and was enacted without proper authority; and (2) Plaintiffs failed to show that irreparable harm would result in the absence of a TRO. View "Bentonville School District v. Sitton" on Justia Law
Boyd v. Payne
The Supreme Court affirmed the decision of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.After a jury trial, Appellant was convicted of aggravated robbery and theft of property. In his pro se petition for writ of habeas corpus Appellant argued that a different standard of review should be applied to habeas cases, he was actually innocent, his constitutional rights were violated, and the evidence was insufficient to sustain his conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ or that the circuit court erred by denying habeas relief. View "Boyd v. Payne" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Johnson v. Wright
The Supreme Court affirmed the order of the circuit court denying Appellants' motion for an emergency injunction that sought the removal of three members of the Eureka Springs City Advertising and Promotion Commission (CAPC), holding that there was no error.On appeal, Appellants argued (1) Carol Wright's appointment to the CAPC violated Ark. Const. art. 19, 3, and (2) the appointments of Melissa Green and Harry Meyer to the CAPC violated Ark. Code Ann. 14-4-107(a)(2). The Supreme Court affirmed, holding (1) the circuit court correctly concluded that Wright's CAPC appointment was not constitutionally prohibited; and (2) the circuit court did not err when it determined that Green and Meyer were qualified to serve as CAPC commissioners despite being sitting council members at the time of their appointments. View "Johnson v. Wright" on Justia Law
Posted in:
Constitutional Law, Government & Administrative Law
Arkansas Department of Health v. Solomon
The Supreme Court affirmed in part and reversed in part the order of the circuit court denying the State's motion to dismiss and granting a preliminary injunction in favor of Plaintiff, holding that the preliminary injunction was granted erroneously.Plaintiff, a hearing-instrument dispenser whose license was not renewed, brought this action against the Arkansas Department of Health, the Secretary of Health, and Arkansas Board of Hearing Instrument Dispensers, and the Executive Director of the Board of Hearing Instrument Dispensers (collectively, the State), arguing that the Board's refusal to provide him a proper renewal notice and a hearing violated his due process and equal protection rights and was an arbitrary and capricious abuse of the Board's power. The circuit court granted Plaintiff's request for a temporary injunction and declaratory relief. The Supreme Court reversed in part, holding (1) Plaintiff adequately pleaded a due process claim; (2) Plaintiff's equal protection claim was barred by sovereign immunity; and (3) because the preliminary injunction order contained no findings on irreparable harm or likelihood of success on the merits, the case must be remanded for findings in accordance with Ark. R. Civ. P. 65(d)(1). View "Arkansas Department of Health v. Solomon" on Justia Law
Thurston v. League of Women Voters of Ark.
The Supreme Court affirmed the judgment of the circuit court denying John Thurston's motion to dismiss this action based on sovereign immunity, holding that Thurston was not entitled to sovereign immunity.Plaintiffs, the League of Women Voters of Arkansas and Arkansas United and several individuals, filed suit against Defendants, including Thurston in his official capacity as the Secretary of State, alleging that four acts passed by the 93rd Session of the Arkansas General Assembly were unconstitutional. Thurston filed a motion to dismiss based on sovereign immunity, which the circuit court granted. The Supreme Court affirmed, holding that Thurston was not entitled to sovereign immunity under the facts of this case. View "Thurston v. League of Women Voters of Ark." on Justia Law
Posted in:
Constitutional Law
Gay v. State
The Supreme Court affirmed the supplemental order of the circuit court denying Ark. R. Crim. P. 37 relief, holding that the circuit court did not err.Defendant was convicted of capital murder and sentenced to death. Defendant later sought postconviction relief, which the circuit court denied. The Supreme Court affirmed, holding (1) Defendant was not denied the right to a fair and impartial jury; (2) the circuit court did not clearly err in denying Defendant's ineffective assistance of counsel arguments; (3) Defendant's challenges to the third death-penalty verdict form did not constitute grounds for relief under Rule 37; (4) Defendant's challenges to the verdict forms did not constitute grounds for relief; and (5) Defendant's remaining allegations of error were without merit. View "Gay v. State" on Justia Law
Halliburton v. State
The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court did not err in denying relief.In denying and dismissing Appellant's petition, the circuit court found that the criminal information in this case was not deficient and that Appellant's counsel provided effective assistance. The Supreme Court affirmed, holding that, contrary to Appellant's contention on appeal, the criminal information complied with Ark. Const. art. VII, 49. View "Halliburton v. State" on Justia Law
Thomas v. State
The Supreme Court affirmed the trial court's judgment denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant's claims lacked merit.Appellant was convicted of capital murder and sentenced as a habitual offender to life imprisonment without parole. In his postconviction petition, Appellant argued, among other things, that his counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his allegations of error. View "Thomas v. State" on Justia Law
Medicanna, LLC v. Arkansas Department of Finance & Administration
The Supreme Court dismissed the circuit court's dismissal of Plaintiff's lawsuit against the Arkansas Department of Finance and Administration, Arkansas Alcoholic Beverage Control Division, Arkansas Medical Marijuana Commission (collectively, State Defendants) and Nature's Herbs and Wellness of Arkansas, LLC, holding that the Court lacked jurisdiction.Plaintiff brought this suit alleging violations of the Arkansas Medical Marijuana Commission's administrative rules, the Administrative Procedure Act, and Plaintiff's equal protection and due process rights. The circuit court concluded that Plaintiff lacked standing to bring its lawsuit and dismissed the complaint. The Supreme Court dismissed Plaintiff's appeal, holding that because the record was not filed within ninety days from the filing of the first notice of appeal this Court lacked jurisdiction over the appeal. View "Medicanna, LLC v. Arkansas Department of Finance & Administration" on Justia Law