Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's motion asking the Court to proceed with a belated appeal of a judgment reflecting his conviction on drug-related charges, holding that the trial court did not err in finding that Petitioner waived his right to appeal and that trial counsel had performed within an objectively reasonable standard.As grounds for the motion, Petitioner asserted that he asked counsel to appeal. The matter was remanded for a hearing. The trial court ultimately concluded that Petitioner waived his right to appeal and that counsel acted within an objective standard of reasonableness in not pursuing an appeal. The Supreme Court affirmed, holding that the trial court's conclusions were supported by the transcript and were not clearly erroneous. View "Smith v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.5, holding that the performance of Appellant's trial counsel was not deficient.Appellant was convicted of capital murder and sentenced to death. Appellant later filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.5 alleging, among other claims, that trial counsel was ineffective concerning the mitigating circumstances presented to the jury and the failure to call any witnesses but his sister at the sentencing phase. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err when it denied Appellant's claim that he received ineffective assistance of counsel during the sentencing phase. View "Johnson v. State" on Justia Law

The Supreme Court denied Petitioner's second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and second petition for writ of certiorari, holding that Petitioner was not entitled to either coram nobis relief or issuance of a writ of certiorari.In two separate trials, Petitioner was convicted of the rapes of two girls and the rape of a five-year-old child and burglary. Petitioner subsequently filed multiple petitions for psostconviction relief, including the instant petitions for coram nobis relief and seeking issuance of a writ of certiorari. The Supreme Court denied coram nobis relief, holding (1) the claims raised in Petitioner's second coram nobis petition that reasserted claims raised in Petitioner's first coram nobis petition were an abuse of the writ; and (2) the remaining claims were either outside the scope on which the writ may issue or did not establish that Petitioner was entitled to coram nobis relief. The Court also denied Petitioner's petition for writ of certiorari, holding that the arguments in the petition could have been raised at trial or on direct appeal. The Court further denied Petitioner's motion for appointment of counsel as unwarranted and motion to withdraw as moot. View "Lukach v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's claims for postconviction relief raised under Ark. R. Crim. P. 37.1, holding that none of counsel's alleged errors created a reasonable probability of a different outcome had they not occurred.In denying postconviction relief, the trial court held that the alleged deficient actions of trial counsel were based on reasonable strategic and legal grounds and that counsel's alleged errors would not have changed the outcome of the trial. The Supreme Court affirmed, holding that to the extent trial counsel's performance arguably satisfied the first prong of Strickland, the failure did not satisfy the second prong - that Appellant's counsel's error was sufficiently prejudicial as to show a reasonable probability of a different outcome. View "Reynolds v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Appellant's action against Baptist Health appellees and John Hearnsberger, M.D., holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of disputed discovery.Appellant, a surgeon, was on the medical staff of Baptist Health from 2003 until 2011, when his appointment and clinic privileges at Baptist Health Medical Center-Little Rock were terminated, effective immediately. Baptist Health also reported the suspension of Appellant's clinical privileges to the Arkansas State Medical Board, which, in 2014, revoked Appellant's license. Appellant appealed the revocation, and his license was reinstated. In 2011, Appellant filed a lawsuit against Baptist Health and several individuals, asserting several claims. The circuit court entered a consent order dismissing the Medical Board and Dr. Hearnsberger in his official capacity. The circuit court then granted summary judgment on Appellant's remaining claims. The Supreme Court reversed in part, holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of discovery, and the discovery error was not harmless as to Appellant's discrimination and tortious-interference claims. View "Williams v. Baptist Health" on Justia Law

The Supreme Court affirmed Appellant's conviction of capital murder, holding that the evidence was sufficient to sustain the conviction and that the circuit court did not err in denying Appellant's motion to suppress tracking data generated by his cellphone.On appeal, Appellant argued that the trial court erred by denying his directed-verdict motion because the evidence supported the defense's theory of the case that he did not intend to shoot the victim. Further, Appellant argued that the court abused its discretion in denying his motion to suppress evidence obtained from the seizure of AT&T phone records. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the capital murder conviction; and (2) the circuit court correctly denied the motion to suppress. View "Thomas v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition.Appellant was found guilty of two counts of delivery of a controlled substance and one count of maintaining a drug premises. In his habeas petition, Appellant argued that he was actually innocent because his arrest and conviction was based on the false testimony of a witness who had a lengthy criminal history. Appellant further argued that the writ should issue because he was not afforded effective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims regarding the witness's credibility do not constitute a valid assertion that he was being unlawfully detained; and (2) Appellant did not actually connect an allegation of ineffective assistance of counsel to his allegation that he was unlawfully detained. View "Cave v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for mistrial, holding that the circuit court's decision to admit into evidence a translation of a letter Defendant wrote in Spanish did not violate Ark. R. Evid. 1009 or Defendant's Sixth Amendment right to confrontation.Defendant was convicted of rape. On appeal, the Supreme Court held (1) there was no reversible error as a result of the bailiff's response to the jury foreman's question regarding the verdict forms, which resulted in the foreman mistakenly signing the forms for both rape and attempted rape, as shown by polling the members of the jury individually; and (2) Defendant did not have a constitutional right to confrontation because the translated statements were attributable to Defendant and, therefore, nontestimonial, and the accompanying affidavit to the letter substantially complied with Rule 1009. View "Garcia-Chicol v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had the capacity to knowingly and intelligently waive his postconviction remedies, including his Ark. R. Crim. P. 37.5 petition, was not clearly erroneous and affirmed the circuit court's dismissal of Defendant's Rule 37.5 petition, holding that the court did not err.Defendant was convicted was capital murder and other crimes. Defendant later filed for postconviction relief pursuant to Ark. R. Crim. P. 37.5, arguing that counsel was constitutionally ineffective for failing to investigate sufficiently whether he was intellectually disabled. Counsel subsequently advised the circuit court that Defendant desired to waive his postconviction remedies, including his Rule 37.5 petition, which counsel asked the court to dismiss. After a hearing to determine whether Defendant had the capacity to waive his postconviction remedies, the circuit court concluded that Defendant's waiver was made knowingly and intelligently. The Supreme Court affirmed, holding that the circuit court did not err in dismissing Defendant's Rule 37.5 petition. View "Lard v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's illegal exaction suit against the City of Blytheville and its Sewer Department (collectively, the City), holding that the circuit court properly granted summary judgment.In her complaint, Plaintiff claimed that a $5 fee for sewer system repairs and upgrades, imposed pursuant to a city ordinance, was a tax and constituted an illegal exaction in violation of article 16, section 13 of the Arkansas Constitution. The circuit court granted the City's motion for summary judgment and dismissed all of Plaintiff's claims with prejudice. The Supreme Court affirmed, holding that the circuit court correctly found that the fee was not a tax and, therefore, not an illegal exaction. View "Watson v. City of Blytheville" on Justia Law