Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief without holding an evidentiary hearing, holding that there was no error.Petitioner was convicted of first-degree murder and sentenced to life imprisonment without parole. In his petition for postconviction relief, Petitioner alleged that his counsel was ineffective for failing to develop the defense of provocation, among other things. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court's finding that Petitioner did not receive ineffective assistance of counsel was not clearly erroneous. View "Coakley v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to raise allegations that warranted coram nobis relief.Petitioner was found guilty of the rape of his minor daughter and sentenced to life imprisonment. In his petition for coram nobis relief, Petitioner argued that his daughter had recanted her trial testimony, his daughter perjured herself, and his trial counsel was ineffective. The Supreme Court denied the petition, holding that Petitioner failed to establish that he was entitled to the writ. View "Chunestudy v. State" on Justia Law

The Supreme Court reversed the circuit court's order finding that both Rule 2.13(b)(5) of the Casino Gaming Rules and Ark. Code Ann. 27-117-101(b) are unconstitutional, holding that the circuit court erred.In 2019, the Arkansas Racing Commission (ARC) adopted Rule 2.13(5)(b) (the Rule) of the ARC-Casino Gaming Rules, which provides that letters of support must be from the county judge, quorum court, or mayor holding office at the time of the submission of an application for a casino license. The General Assembly subsequently passed Act 371 of 2019 (the Act), which was identical to Rule 2.13(5)(b) and is codified at Ark. Code Ann. 23-117-101. Appellant applied for a casino license in May 2019, but the application was denied. Appellant filed the underling litigation challenging the denial of a license and the constitutionality of the Act. The circuit court declared that Rule and the Act were unconstitutional because they imposed an additional qualification to Arkansas Constitutional Amendment 100. The Supreme Court reversed, holding (1) the Rule is consistent with Amendment 100 and does not impose an additional requirement; and (2) the Act is consistent with Amendment 100 and does not impose an additional requirement. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law

The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law

The Supreme Court denied Petitioner's second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and seeking the appointment of postconviction counsel, holding that Petitioner failed to raise a cognizable claim for issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to a term of life imprisonment plus a term of 180 months. The Supreme Court affirmed. In the instant coram nobis petition, Petitioner argued that he was entitled to relief due to a coerced guilty plea, the failure of the prosecutor or his counsel to advise him of the spousal privilege in violation of Brady v. Maryland, 373 U.S. 83 (1963), and ineffective assistance of both trial counsel and postconviction counsel. The Supreme Court denied the writ and denied Petitioner's motion for appoint of counsel as moot, holding that Petitioner's claims were not cognizable in a coram nobis proceeding. View "Gordon v. State" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se civil rights complaint filed pursuant to the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108, in which he alleged that Arkansas Department of Correction (ADC) officials violated his constitutional rights, holding that the circuit court did not err in dismissing the complaint.Appellant sued Appellees in their official and individual capacities, alleging that they had violated his constitutional rights to free speech, free exercise of his religion, access to the court, due process, and equal protection. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that Appellees were immune from liability because Appellant failed to raise claims that demonstrated the deprivation of a constitutional right. View "Muntaqim v. Payne" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis alleging that he was denied effective counsel prior to his criminal trial and that this violation of his Sixth Amendment right entitled him to coram nobis relief, holding that Petitioner was not entitled to relief.Petitioner was convicted of two counts of capital murder and one count of second-degree murder and sentenced to life imprisonment without parole on the capital murder charges. Petitioner later filed his coram nobis petition, raising claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner's allegations of ineffective assistance of counsel did not support issuance of the writ of error coram nobis. View "Hall v. State" on Justia Law

The Supreme Court answered a certified question in the negative and held that Ark. Code Ann. 27-34-106(a) does not violate the separation of powers doctrine under article 4, section 2, and Amendment 80, section 3 of the Arkansas Constitution.The underlying wrongful death and survival action arose from an accident in which Defendants negligently caused a vehicle collision. A two-year-old girl, who was in the cab of a pickup at the time of the accident and was not restrained in a child safety seat, was killed. Defendants asserted fault on the part of the driver of the pickup truck. Plaintiff then filed a motion for partial summary judgment with respect to comparative fault and nonparty fault related to child-safety restraint nonuse, arguing that the defense was precluded as a matter of law by section 27-34-106(a). The Supreme Court answered a certified question about the issue, holding that section 27-34-106(a) - a legislative pronouncement that failing to use a child-safety seat is not a negligent act and therefore cannot be used to compare the injured plaintiff's fault to the fault of the defendant - is more substantive than procedure and does not constitute a violation of the separation of powers doctrine. View "Edwards v. Thomas" on Justia Law

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