Justia Arkansas Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Ward v. State
The Supreme Court affirmed Defendant's conviction of first-degree murder and aggravated assault on a law enforcement officer, holding that the circuit court did not err in denying Defendant's motions for directed verdict on both charges.Defendant was charged with capital murder with an enhancement for using a firearm and other offenses. After a jury trial, Defendant was convicted of the lesser-included offense of first-degree murder, aggravated assault on a law enforcement officer, possession of a defaced firearm, resisting arrest, fleeing, and obstructing governmental operations. Defendant was sentenced to an aggregate term of two life sentences. The Supreme Court affirmed, holding the circuit court did not err in denying Defendant's motions for directed verdict as to his convictions for first-degree murder and aggravated assault on a law enforcement officer because there was sufficient proof presented to the jury that Defendant was capable of forming the requisite mental state given his provisional diagnosis of schizophrenia. View "Ward v. State" on Justia Law
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Criminal Law
Bridges v. State
The Supreme Court affirmed Appellant's conviction of capital murder, aggravated robbery, theft of property, and a firearm sentencing enhancement, holding that Appellant was not entitled to relief on his allegations of error.After a jury trial, Appellant was convicted of the above crimes and sentenced to an aggregate term of life imprisonment without parole plus ten years. The Supreme Court affirmed his convictions and sentences, holding (1) Appellant's challenge to the sufficiency of the evidence based on the State's failure to negate his justification defense was unpreserved; (2) Appellant's argument that the trial court erroneously denied his motion for a mistrial was unpreserved for appeal; and (3) the circuit court did not abuse its discretion in refusing to submit certain language in its justification instruction to the jury. View "Bridges v. State" on Justia Law
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Criminal Law
Doerhoff v. State
The Supreme Court affirmed the judgment of the trial court convicting Appellant of first-degree murder and sentencing him to a term of life imprisonment, holding that Appellant was not entitled to relief on his allegations of error.On appeal, Appellant argued that the circuit court erred by giving a non-model jury instruction regarding justification and by refusing to give his proffered jury instruction regarding excessive force. The Supreme Court disagreed and affirmed, holding that the circuit court (1) did not abuse its discretion in submitting a non-model jury instruction to the jury; and (2) did not abuse its discretion in refusing to submit Appellant's proffered no-model excessive force instruction to the jury. View "Doerhoff v. State" on Justia Law
Posted in:
Criminal Law
Bishop v. State
The Supreme Court affirmed Defendant's conviction, rendered after a jury trial, of capital murder and his sentence of life imprisonment without parole, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held that the circuit court (1) did not err by denying Defendant's motions to suppress evidence from the traffic stop because law enforcement had reasonable suspicion that Defendant was a felon in possession of a firearm; (2) did not err in denying Defendant's motions to suppress evidence from his detention and arrest because the same facts that provided reasonable suspicion for the initial stop provided reasonable suspicion for his pat-down and arrest; and (3) did not err by permitting the State to introduce videos containing statements made by law enforcement officers. View "Bishop v. State" on Justia Law
Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership
The Supreme Court affirmed the judgment of the circuit court concluding that the Arkansas Racing Commission's (ARC) decision to award the Pope County casino license to Cherokee Nation Business, LLC (CNB) and Legends Resort and Casino, LLC (Legends) was a "legal nullity, void and of no effect," holding that there was no error.Gulfside Casino Partnership sought a declaratory judgment that the ARC's actions in awarding the license to CNB and Legends were unconstitutional, constituted and ultra vires act, and violated the Administrative Procedure Act. The circuit court granted summary judgment for Gulfside, ruling that the ARC acted ultra vires, in violation of amendment 100 to the Arkansas Constitution. The Supreme Court affirmed, holding that the ARC acted ultra vires in issuing the license to CNB. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law
Madole v. State
The Supreme Court affirmed Defendant's convictions and sentences for aggravated residential burglary, attempted first-degree murder, first-degree battery, residential burglary, breaking or entering, theft of a firearm, and second-degree criminal impersonation, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant's attorney, pursuant to Anders v. California, 386 U.S. 738 (1967), and Arkansas Supreme Court Rule 4-3(b), filed a motion to withdraw as counsel and a no-merit brief stating that any issues raised on appeal would be "wholly frivolous." The Supreme Court affirmed Defendant's convictions and sentence and granted counsel's motion to withdraw, holding that the pro se points submitted by Defendant for consideration by the Court were unavailing. View "Madole v. State" on Justia Law
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Criminal Law
Wilder v. State
The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of rape, three counts of first-degree sexual assault, and two counts of sexual indecency with a child and sentencing him to two terms of life imprisonment, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the circuit court abused its discretion by admitting testimony of a certain witness under the pedophile exception to Ark. R. Evid. 404(b). The Supreme Court affirmed, holding (1) Defendant's first argument was not preserved for appellate review; (2) Defendant's argument that the circuit court erred in denying his motion for a mistrial was not preserved; and (3) the circuit court did not err in excluding evidence of the victims' prior sexual conduct pursuant to the rape-shield statute set forth in Ark. Code Ann. 16-42-101(c). View "Wilder v. State" on Justia Law
Wofford v. State
The Supreme Court affirmed Defendant's conviction of capital murder and his sentence to life in prison, holding that substantial evidence supported the conviction.After a jury trial, Defendant was convicted of the murder of his ex-wife and sentenced to life imprisonment. As his sole point on appeal, Defendant argued that there was insufficient evidence supporting his conviction, and therefore, the trial court erred in denying his motion for a directed verdict. The Supreme Court disagreed and affirmed, holding that there was substantial evidence to support Defendant's capital murder conviction, and there was no error with respect to the jury's rejection of Defendant's affirmative defense argument. View "Wofford v. State" on Justia Law
Petty v. State
The Supreme Court remanded this case to the circuit court, holding that remand was required to accurately settle the record, specifically concerning Defendant's exhibit 1, a conventionally-filed physical disk that was submitted as part of the record but contained no files.Defendant was convicted of first-degree murder and sentenced to life imprisonment with a fifteen-year enhancement for firearm use. At issue on appeal was whether the circuit court erred in denying Defendant's motion for a mistrial during the guilt phase of trial. The Supreme Court remanded the case, holding that remand was required to rectify gaps in the record. View "Petty v. State" on Justia Law
Posted in:
Criminal Law
Andrews v. Payne
The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition and amended petition for declaratory judgment and writ of mandamus wherein Defendant alleged that the Arkansas Department of Correction illegally changed his discharge date, holding that the circuit court correctly denied the petition and amended petition.After being sentenced in 2007, Defendant was paroled in 2015. Defendant was taken into custody a year later. In his petition and amended petition Defendant alleged that after revocation of his parole and his return to prison, he was informed that his discharge date had been illegally moved. The circuit court denied the petition for failure to state a claim for relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Defendant's petitions for declaratory judgment and writ of mandamus. View "Andrews v. Payne" on Justia Law
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Criminal Law, Government & Administrative Law