Justia Arkansas Supreme Court Opinion Summaries

Rudolph Slater was killed while operating a Yanmar tractor he purchased from Chris Elder Enterprises. The tractor had been manfactured by Yanmar Japan and later sold to Chris Elder Enterprises. Slater's wife, Wanda, filed a wrongful-death action against, among others, Yanmar Japan and Yanmar America, alleging claims for, inter alia, fraud, strict liability, breach of implied and express warranties, and negligence. The circuit court entered judgment in favor of Wanda, awarding her damages in the amount of $2.5 million. The Yanmar defendants appealed. The Supreme Court reversed and dismissed the case, holding (1) the circuit court lacked personal jurisdiction over Yanmar Japan, as there was no evidence to establish that Yanmar Japan had the requisite minimum contacts with the forum to warrant the exercise of general jurisdiction, and there was insufficient proof to show that personal jurisdiction could be predicated on the relationship between Yanmar Japan and its subsidiary, Yanmar America; and (2) the jury's finding that Yanmar America was negligent was not supported by substantial evidence, as Yanmar America owed no duty of care to Rudolph.

Appellant Darcel Tolliver entered in the circuit court a plea of guilty to multiple felony offenses. Appellant was sentenced as a habitual offender to 240 months' imprisonment. Appellant subsequently filed a pro se petition pursuant to Ark. Code Ann. 16-90-111, contending that he was entitled to a reduction in sentence. The petition was dismissed on the ground that it was not timely filed. Appellant appealed and filed motions related to that appeal. The Supreme Court dismissed the appeal and declared the motions moot, holding that the trial court did not err when it dismissed Appellant's petition because Appellant did not timely file his petition for postconviction relief.

Appellant Ricky Strain was convicted by a jury of first-degree murder and was sentenced to 300 months' incarceration. Appellant subsequently filed a timely petition for postconviction relief, which the trial court denied following an evidentiary hearing. The Supreme Court affirmed, holding that trial counsel was not ineffective for failing (1) to preserve the sufficiency-of-the-evidence issue for appeal where Appellant's conviction was supported by substantial evidence, (2) to seek certain jury instructions regarding accomplice liability, (3) to seek severance of Appellant's trial from his codefendant's trial, and (4) to properly argue that a witness's prior inconsistent statement could not be considered by the jury for the truth of the matter stated, as Appellant failed to demonstrate that any objection to the statement or request for a limiting instruction would have been meritorious.

After a jury trial, Petitioner Steven Pinder was found guilty of two counts of rape and sentenced to life imprisonment. The Supreme Court affirmed. Petitioner subsequently filed a petition in the Supreme Court seeking to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, which the Court denied. Before the Court was Petitioner's motion for reconsideration. The Court denied the motion, holding that Petitioner failed to establish that the Court should reconsider its denial of his petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis where Petitioner failed to establish that the Court's denial of his petition was based on an erroneous statement of fact or conclusion of law.

After Lesa Menne was stopped for a traffic violation, a law enforcement officer searched her vehicle and discovered illegal drugs. Menne was charged with possession of marijuana, possession of drug paraphernalia, and possession of methamphetamine. Menne moved to suppress the items seized on grounds that the search was illegal. The circuit court denied the motion. After the subsequent jury trial, Menne was found guilty of the charges. Menne appealed, challenging the circuit court's denial of her motion to suppress. The court of appeals reversed. The Supreme Court vacated the court of appeals and affirmed the judgment of the circuit court, holding that the circuit court's ruling denying Menne's motion to suppress the evidence seized as a result of the officer's search of her vehicle was not clearly against the preponderance of the evidence.

Petitioner Lawrence Martin was convicted of capital murder. The Supreme Court affirmed. Petitioner subsequently petitioned the Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, listing three bases for the writ in his petition. Petitioner also filed motions relating to the petition. The Supreme Court denied the petition and declared the motions moot, holding that Petitioner's claims were largely based upon trial error, rather than hidden or unknown facts, which claims were not cognizable in a coram-nobis proceeding. Therefore, Petitioner failed to meet his burden to show that the writ was warranted.

After a jury trial, Appellant Rodney Jones was convicted of capital murder in the shooting death of his ex-wife. The jury sentenced Appellant to life imprisonment without parole. The Supreme Court affirmed the conviction and sentence, holding (1) certain statements made by the State during closing arguments were not so inflammatory that justice could not be served by continuing the trial, and the circuit court did not abuse its discretion in denying Appellant's motion for a mistrial; and (2) the circuit court did not err in failing to instruct the jury on the lesser-included offenses of reckless manslaughter and negligent homicide.

Petitioner Mitchell Johnson entered a plea of guilty to financial identity fraud, theft by receiving, and misdemeanor possession of a controlled substance. Petitioner subsequently filed a timely pro se petition for postconviction relief. The circuit court denied the petition. Petitioner did not timely file a notice of appeal from the order. Petitioner sought leave to proceed with a belated appeal, contending that the circuit court failed to send him a copy of the order denying his postconviction relief petition, as it was required to do under Ark. R. Crim. P. 37.3(d). The Supreme Court granted the motion, holding that the failure of the court to abide by Rule 37.3(d) established good cause for Petitioner's failure to timely file a notice of appeal.

Appellant Dwight Jackson pled guilty to one count of delivery of a counterfeit substance and was sentenced by the circuit court to ninety-six months' imprisonment. Appellant subsequently filed a petition for postconviction relief, alleging (1) he did not sign his plea agreement in open court and had been coerced into signing the agreement, (2) his plea of guilty was not made voluntarily or knowingly, and (3) the plea statement he signed did not contain the mandatory range of punishment, and the trial court did not explain the range of punishment to him. The circuit court denied the petition. The Supreme Court affirmed, holding that because the record did not contain a transcript of the plea hearing, the Court was unable to conduct an adequate review.

Appellant Clarence Ashby was found guilty of rape, for which a sentence of thirty years' imprisonment was imposed. The court of appeals affirmed. Appellant subsequently filed a pro se petition for writ of habeas corpus, alleging (1) he was denied due process by not being tried in juvenile court, (2) there was no DNA evidence to establish his identity as the offender, (3) witness statement were unreliable and inadmissible, and (4) he was not afforded effective assistance of counsel at trial. The circuit court denied Appellant's petition. Appellant appealed and filed several motions relating to his appeal. The Supreme Court declared the motions moot and dismissed the appeal, holding that because Appellant failed to state cognizable claims, he did not meet his burden of demonstrating a basis for a writ of habeas corpus to issue.