Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's claim for habeas relief on the grounds that Petitioner's allegations should have been raised at trial or in a timely petition under Ark. R. Crim. P. 37.1, holding that Petitioner failed to raise a claim for issuance of the writ.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner later filed his habeas corpus petition, arguing that his conviction was void because he was tried by an eleven-member jury. The circuit court dismissed the action. The Supreme Court affirmed, holding that Petitioner's claim constituted a due process claim that was not cognizable in a habeas proceeding and should have been raised on direct appeal or in a petition for postconviction relief. View "Phillips v. Culpepper" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying the motion to dismiss this action against the Arkansas Department of Education, members of the Arkansas State Board of Education, and the Commissioner of Education (collectively, the State Board), holding that the circuit court correctly denied sovereign immunity on the constitutional delegation of authority claim.Several parents and grandparents of students in the Little Rock School District brought this lawsuit challenging the State Board's continued control of LRSD through limitations placed on a new school board. The State Board filed a motion to dismiss based on sovereign immunity and lack of subject matter jurisdiction. The circuit court denied the motion to dismiss. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court lacked subject matter jurisdiction over Plaintiffs' Administrative Procedure Act claim; (2) Plaintiffs failed to sufficiently plead an illegal-acts or ultra vires exception to sovereign immunity under Ark. Code Ann. 6-15-2917(c); and (3) the circuit court properly denied sovereign immunity on Plaintiffs' constitutional delegation of authority claim because the sufficiently pled challenge to the constitutionality of Ark. Code Ann. 6-15-2916 and -2917 overcame sovereign immunity. View "Arkansas Department of Education v. McCoy" on Justia Law

The Supreme Court dismissed on direct appeal the order of the circuit court denying in part Monsanto Company's motion for judgment on the pleadings and concluding that the Arkansas State Plant Board's Regulation 7 does not violate the Commerce Clause of the federal Constitution and is not invalid as being enacted by an unconstitutionally appointed board, holding that the circuit court did not err.The circuit court denied Monsanto's motion challenging the constitutionality of Regulation 7 and further granted judgment in favor of Monsanto on its claim that Ark. Code Ann. 2-16-206, the statute governing appointment of Board members, is an unconstitutional delegation of the appointment power. The Supreme Court dismissed on direct appeal and affirmed on cross-appeal, holding (1) the circuit court did not err in ruling that Regulation 7 does not violate the Commerce Clause or in rejecting Monsanto's argument that Regulation 7 was enacted by an unconstitutionally appointed board; and (2) the circuit court properly ruled that section 2-16-206(a)(5)-(13) is an invalid delegation of the appointment power. View "Monsanto Co. v. Arkansas State Plant Board" on Justia Law

The Supreme Court reversed the judgment of the circuit court finding that Ark. Code Ann. 2-16-206(a), which sets forth the appointment process for members of the Arkansas State Plant Board (ASPB), was constitutional, holding that the circuit court erred in ruling that the statute is constitutional.Appellant filed a complaint generally challenging the ASPB's dicamba cutoff rule and the denial of a petition for rule making submitted by Appellants and also sought a declaration that section 2-16-206(a) is unconstitutional. The circuit court concluded that the challenged rule was void ab initio and null and void as to Appellant. On remand from the Supreme Court the circuit court found that section 2-16-206(a) was constitutional. The Supreme Court reversed, holding that section 2-16-206(a) is unconstitutional. View "McCarty v. Arkansas State Plant Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's postconviction petition filed under Ark. R. Crim. P. 37, holding that the circuit court did not err.Defendant was convicted of four counts of rape and one count of terroristic threatening. The Supreme Court affirmed. Thereafter, Defendant filed amended petition under Rule 37 alleging six grounds for relief. The circuit court denied the petition. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in finding that trial counsel provided constitutionally effective assistance of counsel; and (2) the circuit court did not abuse its discretion in striking the testimony of Defendant's expert witness. View "Joyner v. State" on Justia Law

The Supreme Court dismissed this interlocutory appeal brought by the State pursuant to Ark. R. App. P.-Crim. 3 arguing that the circuit court erred in granting Defendant's motion to suppress medical records obtained through a prosecutor's subpoena, holding that the appeal was not a proper State appeal under Rule 3.The State charged Defendant with one count of negligent homicide after he rear-ended a vehicle, causing an accident that killed a minor. Defendant filed a motion to suppress the results of a urine sample collected at the hospital and medical records that were obtained by the State, which included the results of a blood test taken as part of Defendant's medical treatment. The circuit court granted the motion to suppress, and the State appealed. The Supreme Court dismissed the appeal, holding that the State did not have a proper basis to appeal. View "State v. Kirchner" on Justia Law

The Supreme Court affirmed the judgment of the circuit court granting Petitioners' request for a preliminary injunction and finding that the entirety of Ark. Code Ann. 7-9-601(b) is unconstitutional, holding that the circuit court did not abuse abuse its discretion in granting the preliminary injunction.Petitioners filed a complaint arguing that section 7-9-601(b)'s requirements requiring sponsors of initiatives to obtain federal background checks from the Arkansas State Police are unconstitutional and should be enjoined. The circuit court granted Petitioners' request for a preliminary injunction, finding that the entirety of section 7-9-601(b) is unconstitutional and enjoining Respondents from applying its provisions. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in determining that Petitioners demonstrated a likelihood of success on the merits and that irreparable harm would result in the absence of an injunction. View "Thurston v. Safe Surgery Arkansas" on Justia Law

The Supreme Court denied the State's petition for a writ of certiorari to the circuit court's order granting a mistrial as to both the guilt and penalty phases of Defendant's capital murder trial when the event precipitating the mistrial occurred after the jury found Defendant guilty, holding that the circuit court correctly determined that the unique circumstances in this case required a mistrial as to both the guilt and penalty phases of the trial.After a retrial, a jury convicted Defendant of capital murder and first-degree battery. During the penalty phase of trial, the State's witness lunged toward Defendant in an apparent effort to assault him. After the jury left the courtroom, Defendant's counsel moved for a mistrial of the sentencing proceeding. The circuit court declared a mistrial as to both the guilt and the penalty phases of the trial. The State filed a petition for writ of certiorari seeking an order directing the circuit court to preserve the guilty verdict and conduct a new sentencing hearing only. The Supreme Court denied the petition, holding that the circuit court did not err or exceed its jurisdiction in declaring a mistrial with respect to the guilt phase of the trial. View "State v. Torres" on Justia Law

The Supreme Court affirmed in part, reversed and remanded in part, and dismissed as moot in part the circuit court's order granting summary judgment in favor of the the City of North Little Rock, the City's mayor, certain City Council members, and other City officials and dismissing Plaintiff's action challenging the City's decision to condemn certain property, holding that some of Plaintiff's arguments on appeal were moot.Specifically, the Supreme Court held (1) Plaintiff's argument that the City Council proceeding did not contain any factual findings to support the condemnation and demolition of Plaintiff's property was moot; (2) there was no longer a justiciable controversy regarding Plaintiff's failure-to-exhaust argument, and therefore, the issue was moot; (3) summary judgment was properly granted to the City as to argument that the City's condemnation ordinance violated due process; (4) the circuit court did not err in granting summary judgment on the claim that the City's ordinance was unconstitutionally vague; and (5) the circuit court did not abuse its discretion in declining to grant Plaintiff's renewed motion to strike the City's amended answer and affirmative defenses. View "Convent Corp. v. City of North Little Rock" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the circuit court failed to make specific written findings of fact and conclusions of law on Appellant's last claim of ineffective assistance of counsel.Appellant was convicted of capital murder and sentenced to death. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, among other things, that his trial counsel was ineffective for failing adequately to investigate and challenge aggravation factors. The circuit court denied the petition. The Supreme Court reversed, holding that the circuit court failed to make findings of fact or conclusions of law addressing Appellant's last claim of ineffective assistance of counsel, as required under Rule 37.5(i). The Court remanded the case to the circuit court for entry of an order that complies with Rule 37.5(i). View "Gay v. State" on Justia Law