Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Gordon v. State
Appellant was convicted of first-degree murder and sentenced to a term of life imprisonment plus fifteen years. On appeal, Appellant argued that the circuit court abused its discretion (1) in admitting evidence of a jailhouse fight in the State's rebuttal case, and (2) in limiting the testimony of an expert witness. The Supreme Court affirmed, holding (1) Appellant failed to preserve his first argument for review on appeal; and (2) the circuit court did not abuse its discretion in excluding the expert witness's testimony on the subject of what a person experiences when he or she shoots another person. View "Gordon v. State" on Justia Law
Brown v. State
After a jury trial, Appellant was convicted of the rape of B.B., his minor stepdaughter, and sentenced to a term of imprisonment for life. Appellant appealed, arguing that the circuit court erred in (1) denying his motion for the trial judge to recuse because the trial judge had served as a deputy prosecuting attorney on an earlier case in which Appellant had been charged with raping S.S., who testified at the instant trial; (2) admitting testimony under the pedophile exception to Ark. R. Evid. 404(b) and under Ark. R. Evid. 403; and (3) granting the State's motion in limine to exclude evidence Appellant intended to offer concerning his sexual relationship with his wife. The Supreme Court affirmed, holding (1) the trial judge did not abuse her discretion in denying Appellant's request that she recuse, as Appellant failed to demonstrate actual bias or that the trial judge was required to recuse; (2) the trial court did not err in admitting the disputed testimony; and (3) Appellant failed to preserve his final argument for the Court's review. View "Brown v. State" on Justia Law
Arnold v. State
Appellant appealed from a circuit court order reflecting his convictions for capital murder and aggravated robbery and his sentence to life imprisonment without parole. Appellant's sole assertion on appeal was that the circuit court erred in refusing to hear testimony from a juror in support of his motion for new trial based on Ark. R. Evid. 606(b). The Supreme Court affirmed Appellant's convictions and sentence, holding that the circuit court did not abuse its discretion in prohibiting the testimony and denying Appellant's motion for new trial, as Rule 606(b) states plainly that a juror may not testify as to the effect of anything upon his mind as influencing him to assent to the verdict. View "Arnold v. State" on Justia Law
Winbush v. State
Petitioner Jason Winbush was found guilty by a jury of murder in the first degree and sentenced to 540 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. Petitioner's sole ground for the writ was the claim that the evidence adduced at trial was insufficient to sustain the judgment. The Supreme Court denied the writ, holding that the issue was not cognizable in a coram-nobis proceeding and, rather, was a matter to be settled on direct appeal. View "Winbush v. State" on Justia Law
Rodriguez v. State
Petitioner was found guilty by a jury of murder in the first degree in the stabbing death of Gabino Mendoza. Petitioner was sentenced to life imprisonment. The Supreme Court affirmed. Petitioner subsequently filed a petition with the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, claiming (1) the prosecution violated his right to due process by coercing three persons into making false statements and that the three later provided affidavits attesting to the coercion, and (2) his attorney did not afford him effective assistance of counsel. The Supreme Court affirmed, holding that Petitioner's claims did not state a basis for the writ. View "Rodriguez v. State" on Justia Law
Pepper v. Garrett
Following her resignation as a dental assistant in the dental office of Appellee, Appellant sued Appellee for sexual harassment and outrage. On remand, the circuit court granted Appellee's motion for partial summary judgment, concluding that Appellant's state-law claim for sexual harassment failed because the material facts established that Appellee did not have enough employees for a cause of action to exist against him pursuant to the Arkansas Civil Rights Act (ACRA). On interlocutory appeal, Appellant claimed the numerosity requirement of the ACRA violated the state and federal Constitutions. The Supreme Court dismissed without prejudice Appellant's appeal, holding that the circuit court's order was not final and appealable because it did not satisfy the requirements of Ark. R. Civ. P. 54(b). View "Pepper v. Garrett" on Justia Law
Huff v. State
A jury convicted Appellant of aggravated residential burglary, aggravated robbery, kidnapping, terroristic threatening in the first degree, and battery in the second degree. Appellant appealed, arguing that the trial court erred in (1) denying his motion for a directed verdict to reduce the kidnapping charge from a Class Y felony to a Class B felony, and (2) admitting testimony concerning his previous uncharged conduct. The Supreme Court affirmed, holding (1) the evidence was sufficient for the jury to find Defendant guilty of kidnapping as a Class Y felony, and therefore, the circuit court did not err in denying Appellant's motion for a directed verdict; and (2) the trial court did not abuse its discretion in admitting the testimony at the sentencing phase of the trial.
View "Huff v. State" on Justia Law
Craigg v. State
A jury convicted Appellant of rape and sentenced him to life in prison without the possibility of parole. On appeal, Appellant argued that the trial judge erred by allowing the introduction of a prior offense into evidence under Ark. R. of Evid. 404(b). Appellant's principal point on appeal was that the pedophile exception was inapplicable to his prior conviction because the two offenses were factually dissimilar and temporally improximate and because there was no evidence he had an intimate relationship with either victim. The Supreme Court affirmed, holding that the trial judge did not abuse his discretion in finding that Appellant's prior conviction satisfied the pedophile exception to Rule 404(b), as (1) there were sufficient similarities between the two cases, (2) there was sufficient evidence of intimate relationships; and (3) because Appellant committed both offenses as an adult and assaulted each child victim in the same manner, the trial judge's decision to admit Appellant's relatively old conviction was reasonable. View "Craigg v. State" on Justia Law
Bates v. State
In 2009, judgment was entered reflecting that Petitioner had been found guilty of multiple felony offenses. He was sentenced as a habitual offender to an aggregate term of 504 months' imprisonment. The court of appeals affirmed. The court of appeals' mandate was issued on June 2, 2010. On January 20, 2012, more than eighteen months after the mandate was issued, Petitioner filed a pro se petition for postconviction relief. The trial court denied the petition on the ground that it was untimely filed. The Supreme Court dismissed Petitioner's appeal and declared the motion related to the appeal moot, holding that the trial court did not err in denying the petition because it was untimely filed.
View "Bates v. State" on Justia Law
Walmsley v. Todd
Intervenors were sponsors of a proposed constitutional amendment that would authorize them to own and operate casinos in four specified counties within the state. Respondent was the secretary of state and certified intervenors' proposed amendment for the November 6, 2012 general election. Petitioners were taxpayers, voters, and members of the Arkansas Racing Alliance, a ballot-question committee expressly organized to advocate for the defeat of two proposed constitutional amendments, one of which was intervenors'. In this original action, Petitioners requested that the Supreme Court declare the initiative petition insufficient and the revised ballot title invalid and enjoin Respondent from placing the proposed constitutional amendment on the general election ballot. The Court vacated the certification, holding that the certification of intervenors' revised ballot title was improper because that title was not attached to the petition circulated to, and signed by, the voters. View "Walmsley v. Todd" on Justia Law