Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Charles Goodwin was convicted of attempted capital-felony murder with aggravated robbery as the underlying offense and sentenced to life imprisonment. Petitioner timely filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1. Approximately three-and-one-half years afterwards, Petitioner filed a pro se petition for writ of mandamus, contending that the circuit court judge had not acted on the Rule 37.1 petition in a timely manner. The judge explained the cause of the delay, and the Rule 37.1 petition was acted on by the court. The Supreme Court, therefore, held that the mandamus action was moot. View "Goodwin v. Keaton" on Justia Law

The Carnegie Public Library is located within Carroll County. It and two other libraries within the county are maintained through funds generated by an ad valorem tax. Appellees, the county officials responsible for distribution of the tax proceeds, divided the library tax evenly between the three libraries. Appellants, the Carnegie Library, library board, and two individuals, filed a complaint alleging that, pursuant to section 19 of Act 74 of 1883, the county was required to divide the tax proceeds based on the division of the county into the Eastern and Western Districts, which would result in fifty percent of all tax revenue collected being distributed wholly to the Carnegie Library as the only public library in the Western District. The circuit court dismissed Appellants' complaint, holding (1) section 19 of Act of 1883 was unconstitutional, and (2) the Act did nothing more than create two judicial districts. The Supreme Court dismissed the appeal, holding that a challenge to the distribution of the tax proceeds should have been raised in county court, and therefore, the circuit court lacked jurisdiction, as did the Supreme Court. View "Carnegie Pub. Library of Eureka Springs v. Carrroll County" on Justia Law

Petitioner Al Williams tendered a pro se motion for rule on clerk, seeking to file a motion for belated appeal of a civil order without a certified record. A few days later, Petitioner filed the instant motion to proceed in forma pauperis and thus avoid paying a fee to file the motion for rule on clerk. The Supreme Court dismissed the motion, as it was clear Petitioner would not succeed on appeal where (1) Petitioner demonstrated no basis on which the Court could permit a belated appeal even if the motion for rule on clerk were granted; and (2) Petitioner established no circumstances sufficient to warrant granting the motion to proceed in forma pauperis and permitting the motion for rule on clerk to be filed for the purposes of considering the motion for belated appeal. View "Williams v. Helena Reg'l Med. Ctr." on Justia Law

The City filed a complaint in eminent domain against Zara Thomas, trustee of two revocable trusts, and a motion for an order of immediate possession, seeking to procure a portion of Thomas's property for the purpose of constructing a bike trail. The circuit court granted the City's motion for order of immediate possession, and the City commenced construction on Thomas's property. Thomas appealed. The Supreme Court dismissed the appeal without prejudice, holding that the order did not conclude the parties' rights as to the subject matter in controversy, and therefore, was not a final and appealable order, as the circuit court had not yet addressed the issue of Thomas's right to just compensation and the amount of damages. View "Thomas v. City of Fayetteville" on Justia Law

Petitioner David Daniels was found guilty by a jury of possession of a controlled substance and possession of drug paraphernalia. The court of appeals affirmed. Petitioner subsequently filed a pro se motion seeking at public expense a copy of the transcript lodged on direct appeal, contending that the transcript was necessary to file a petition for writ of habeas corpus and that he was entitled to a copy. Appended to the motion was Petitioner's affidavit of indigency. The Supreme Court denied the motion, holding that Petitioner failed to show the transcript should be provided to him at no cost because he did not establish that there was a timely postconviction remedy available to him. View "Daniels v. State" on Justia Law

Appellant Barry Aaron received two life sentences for his convictions on charges of kidnapping and rape. Appellant subsequently filed two pro se motions referencing an action under Ark. Code Ann. 16-112-201 to -208, or Act 1780. The trial court denied the motions, and Appellant appealed. Before the Supreme Court was Appellant's motion to consolidate the two appeals. The Court declared the motion moot and dismissed the appeals, holding that relief under the Act was foreclosed to Appellant on the basis that he pursued a defense based upon a tactical decision not to have certain evidence disclosed, and therefore, it was clear that Appellant could not prevail on appeal of either of the orders that denied the motions. View "Aaron v. State" on Justia Law

After receiving complaints of narcotic activity, patrol officers began to watch an area around a trailer. An officer opened three trash bags from a nearby dumpster to investigate the names of the adults living in the trailer and discovered items relating to methamphetamine as well as fresh baby diapers. After obtaining a search warrant, which included a justification for nighttime clause because the search would be executed after 8 p.m., the officers discovered methamphetmine being manufactured in the bathroom while three small children were asleep inside the trailer. The circuit court Defendant Mark Tyson's motion to suppress, finding that none of the nighttime-search conditions in Ark. R. Crim. P. 13.2(c) applied to the search. The Supreme Court reversed, holding that the circuit court erred in granting Tyson's motion to suppress where (1) the facts did not provide a basis for reasonable cause for a nighttime search pursuant to Rule 13.2; but (2) the executing officers operated in good faith under U.S. v. Leon, and therefore, the exception to the Court's criminal rules applied to the defective search and seizure. View "State v. Tyson" on Justia Law

This interlocutory appeal stemmed from the circuit court's disqualification of Reggie Koch as counsel for appellants, Ae Samontry and Pornpiemon Phouangmany. Appellants were charged with prostitution and promoting prostitution. Jerry Richard, Samontry's ex-husband, was also charged with promoting prostitution. Richard was represented by Koch. Samontry and Phouangmany were found guilty as charged, and Richard was acquitted of all charges. Samontry and Phouangmany then retained Koch as their attorney and appealed their convictions to the circuit court. The circuit court subsequently granted the State's motion to disqualify Koch as counsel for Appellants based on his previous representation of a material witness, Richard, in the matter. The Supreme Court (1) dismissed the appeal with respect to Samontry, as there was no order contained in the record of this interlocutory appeal disqualifying Koch as counsel for Samontry; and (2) reversed Koch's disqualification as counsel for Phouangmany, as the State failed to meet its burden of proof to support Koch's disqualification in Phouangmany's case. View "Samontry v. State" on Justia Law

Appellant Yvonne Dockery pled no contest to one count of theft pursuant to a negotiated plea. On October 26, Appellant filed a motion to withdraw her no-contest plea. On October 30, the circuit court denied the motion after finding that sentencing had taken place prior to the filing of the motion and the court had lost jurisdiction to set aside the plea. Also on October 30, the court entered a judgment-and-commitment order. The Supreme Court reversed, holding that the circuit court clearly erred in determining whether it had jurisdiction to entertain Appellant's motion where the commitment order was not filed with the circuit clerk until four days after Appellant had filed her motion. Remanded. View "Dockery v. State" on Justia Law

Appellant Billy Culbertson, who was incarcerated at the Arkansas Department of Correction located in Lee County, filed a pro se petition for writ of habeas corpus in the Lee County circuit court. The petition pertained to three criminal judgments on charges to which Appellant had entered pleas of guilty. Appellant argued that he was innocent of the offenses and that he was entitled to be released on a writ of habeas corpus on a number of grounds. Before the Supreme Court was Appellant's motion to file a belated brief on appeal. The Court declared the motion moot and denied the appeal, as Appellant failed to establish that the writ should issue. View "Culbertson v. State" on Justia Law