Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Constitutional Law
Vickers v. Norris
Appellant Dustin Vickers was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed his conviction and sentence. Appellant subsequently filed a petition for writ of habeas corpus in the circuit court of the county in which he was incarcerated, asserting that the circuit court lacked jurisdiction and that the judgment was invalid on its face. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant fell short of establishing that the trial court in his case lacked jurisdiction or that the commitment was invalid on its face, and therefore, there was no basis for a finding that a writ of habeas corpus should issue. View "Vickers v. Norris" on Justia Law
Scott v. State
Pursuant to a negotiated plea agreement, Appellant Mario Scott pled nolo contendere to first-degree murder. Appellant subsequently filed a petition for postconviction relief, alleging ineffective assistance of counsel and asserting that the trial court was without jurisdiction to sentence him because it violated his due-process and Sixth Amendment rights. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that the trial court did not err in denying relief where (1) Appellant did not establish prejudice based on his counsel's alleged error; (2) Appellant's claim that the trial court was without jurisdiction to impose a sentence following his guilty plea was not cognizable in a petition for postconviction relief; and (3) the trial court did not err in failing to hold an evidentiary hearing on the ineffective-assistance claims. View "Scott v. State" on Justia Law
Sartin v. State
Appellant Antonio Sartin was tried and convicted by a jury of aggravated robbery and felony theft of property and sentenced as a habitual offender. The court of appeals affirmed Appellant's convictions. Appellant subsequently filed an amended petition for postconviction relief, alleging that his trial counsel was ineffective (1) in failing to pursue the theory of defense that he was guilty only of theft of property and not aggravated robbery, and (2) in not honoring his request to testify in his own behalf. The circuit court denied the petition without holding a hearing. The Supreme Court affirmed the denial of postconviction relief, holding that the circuit court did not clearly err in denying Appellant's petition on either ground asserted. View "Sartin v. State" on Justia Law
Greer v. State
A jury found Appellant Vince Greer guilty of internet stalking of a child and sentenced him to sixteen years' imprisonment. The court of appeals affirmed. Appellant subsequently filed a petition for postconviction relief in the circuit court, alleging that his defense counsel rendered ineffective assistance. The circuit court denied the petition without a hearing. The Supreme Court affirmed the denial of postconviction relief, holding that the circuit court (1) did not err by denying Appellant's petition without making written findings or conducting a hearing, and (2) did not err in denying Appellant's petition for postconviction relief on the grounds of ineffective assistance of counsel.
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Evans v. State
Petitioner Lavelle Evans was found guilty by a jury of several drug offenses. Petitioner was sentenced as a habitual offender to an aggregate sentence of 960 months' imprisonment. The court of appeals affirmed. Petitioner subsequently filed with the Supreme Court a pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis challenging the judgment, alleging that one of the jurors at his trial was biased. The Court denied the relief sought, holding that Petitioner's claim of juror bias was not cognizable as a ground for a writ of error coram nobis. View "Evans v. State" on Justia Law
Cent. Okla. Pipeline, Inc. v. Hawk Field Servs., LLC
Appellant Central Oklahoma Pipeline successfully bid for the construction of a natural gas pipeline. Appellant subsequently sued the companies that engaged it (the Hawk defendants), and an engineering company (CTS), asserting (1) against the Hawk defendants, claims for breach of contract and a violation of the Arkansas Deceptive Trade Practices Act (ADTPA); and (2) against CTS, negligence or failing to give notice of its requirement to inform Appellant of the necessity of having a contractor's license. Appellant then filed an amended complaint adding Lee Hallmark and several John Does as defendants, contending that they were employees of the Hawk defendants and that their negligence was imputed to the Hawk defendants under the doctrine of respondeat superior. The circuit court granted the defendants' motions for summary judgment. The Supreme Court affirmed, holding that the circuit court did not err in (1) ruling that Ark. Code Ann. 17-25-103(d) barred Appellant's claims for breach of contract and a violation of the ADTPA; (2) determining that section 17-25-103(d) was constitutional; and (3) ruling that Ark. Code Ann. 17-25-313 does not impose a tort duty on engineers who fail to inform prospective bidders that they must have a contractor's license. View "Cent. Okla. Pipeline, Inc. v. Hawk Field Servs., LLC" on Justia Law
Cancun Cyber Cafe & Bus. Ctr., Inc. v. City of N. Little Rock
Cancun Cyber Cafe and Business Center was an internet cafe and business center that operated a sweepstakes promotion whereby Cancun's customers could play casino-style video games to learn whether they had won prizes through the sweepstakes promotion. Cancun filed a complaint for emergency declaratory and injunctive relief and a motion for temporary restraining order (TRO) and preliminary injunction against the city, police chief, and county prosecuting attorney, seeking declarations that, inter alia, Cancun's business and sweepstakes promotion was lawful. The county attorney filed a motion to dismiss Cancun's complaint. The circuit court granted the motion and denied as moot Cancun's motion for TRO and preliminary injunction. The Supreme Court affirmed, holding that because there was no existing legal controversy in this case, Cancun was not entitled to declaratory and injunctive relief, and therefore, the circuit court did not err in granting the prosecuting attorney's motion to dismiss and denying as moot Cancun's motion for TRO and preliminary injunction. View "Cancun Cyber Cafe & Bus. Ctr., Inc. v. City of N. Little Rock" on Justia Law
Tarkington v. Norris
After a jury trial, Appellant Johnny Tarkington was found guilty of aggravated robbery and sentenced, as a habitual offender, to life imprisonment. The Supreme Court affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, making several allegations of error and claiming actual innocence. The circuit court denied Appellant's petition, finding (1) Appellant failed to establish the circuit court's lack of jurisdiction or that his commitment order was facially invalid, and (2) Appellant did not establish a claim of actual innocence based upon scientific evidence that was unavailable at the time of his trial. The Supreme Court affirmed, holding that Appellant's claims were not cognizable for a writ of habeas corpus to issue. View "Tarkington v. Norris" on Justia Law
Samples v. State
Appellant Steven Samples entered into a negotiated plea of guilty to six drug-related charges and was sentenced to 300 months' imprisonment. On December 2, 2009, a judgment-and-commitment order was entered reflecting Appellant's negotiated plea. On December 20, 2010, Appellant filed a motion to correct clerical mistake in his commitment order, asserting that that the date reflected on the judgment did not conform with the agreement he reached in pleading guilty. The circuit court treated Appellant's motion as one seeking postconviction relief and denied the motion. The Supreme Court dismissed the appeal, holding (1) the court properly treated Appellant's motion as one seeking postconviction relief because it sought to correct a judgment that was based on a substantive claim; and (2) the court lacked jurisdiction to consider Appellant's motion because Appellant's postconviction motion to correct was untimely filed. View "Samples v. State" on Justia Law
Rueda v. State
Following a jury trial, Appellant Julian Rueda was convicted of three drug-related offenses and was sentenced to a total of 600 months' imprisonment. The court of appeals affirmed his convictions and sentence. Appellant subsequently filed a pro se petition for postconviction relief, asserting ten claims all alleging that trial counsel was ineffective. The trial court denied each of the allegations made by Appellant in his petition. In his appeal, Appellant contended that the circuit court erred in finding that his trial counsel did not render ineffective assistance in failing to file a motion to dismiss based on a speedy-trial violation. The Supreme Court affirmed, holding that because any motion to dismiss based on speedy trial would have lacked merit, trial counsel was not ineffective for failing to make such a motion, and for this reason, the circuit court did not clearly err in its judgment.
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