Justia Arkansas Supreme Court Opinion Summaries
Burnett v. State
The Supreme Court dismissed this petition brought by Petitioner for writ of certiorari and writ of habeas corpus alleging that the circuit court violated Ark. R. Crim. P. 8 and 9, holding that the petition was moot.The State charged Petitioner with criminal use of a prohibited weapon and criminal acts involving explosives or a destructive device. Thereafter a grand jury indictment was filed in federal district court alleging that Petitioner knowingly made a destructive device and knowingly possessed a destructive device. Petitioner pled guilty to one count of aiding and abetting the possession of a destructive device. Thereafter, Petitioner filed this petition for writ of certiorari and habeas corpus. The State's charges against Petitioner were subsequently nol-prossed. In his petition, Petitioner alleged that he appeared without counsel at his pretrial bail hearing, in violation of rule 9.2, and that the circuit court failed to make specific findings when setting his bail. The Supreme Court dismissed the petition, holding that Petitioner's claims were moot. View "Burnett v. State" on Justia Law
Posted in:
Criminal Law
Cook v. Most Worshipful Grand Lodge
The Supreme Court vacated the order of the court of appeals granting the Grand Lodge's motion to dismiss Plaintiff's appeal from the circuit court order dismissing the complaint based on Plaintiff's failure to file a complete record while, at the same time, denying Plaintiff's motion for writ of certiorari to complete the record, holding that the appeal must be dismissed.In dismissing Plaintiff's complaint the circuit court concluded that the complaint was legally insufficient. Plaintiff filed a notice of appeal but did not receive the transcript when the deadline to file the record passed. The Grand Lodge filed a motion seeking to dismiss the appeal for lack of jurisdiction, which the court of appeals granted. On appeal, Plaintiff argued that he could not have good faith filed a motion for an extension for filing the record with the clerk of the Supreme Court because he could not show that more time was necessary. The Supreme Court vacated the court of appeals' order and granted the Grand Lodge's motion to dismiss this appeal, holding that Plaintiff failed to file an extension order or demonstrate that he was unable to do so and failed to demonstrate that it would be unjust to dismiss his appeal. View "Cook v. Most Worshipful Grand Lodge" on Justia Law
Posted in:
Civil Procedure
Benton School District v. Greer
The Supreme Court held that Ark. Code Ann. 12-9-301, which provides immunity from both suit and liability for certain officials "except to the extent that they have be covered by liability insurance," does not apply to a federal cause of action brought under 42 U.S.C. 1983 but does apply to a state claim brought under the Arkansas Civil Rights Act.Plaintiff filed a complaint against the Benton School District, a principal in the strict (Lori Bacon), and an assistant superintendent (Lisa Gattis). The district court concluded that all Defendants were liable under section 1983 and the Arkansas Civil Rights Act for violating Plaintiff's rights to free speech and to petition the government under the First Amendment. The court granted Bacon and Gattis's motion for summary judgment on qualified immunity grounds but determined that their motion was limited to the extent they were covered by liability insurance. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) section 21-9-301 does not impact a claim brought under section 1983; and (2) the circuit court correctly ruled that section 21-9-301 immunity applies to claims arising under the Arkansas Civil Rights Act. View "Benton School District v. Greer" on Justia Law
Posted in:
Civil Rights, Constitutional 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
Posted in:
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
Posted in:
Criminal Law
Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership
The Supreme Court affirmed the judgment of the circuit court holding that the Arkansas Racing Commission's (ARC) decision to award the Pope County casino license to Cherokee Nation Businesses, LLC (CNB) and Legends Resort and Casino, LLC (Legends) was a "legal nullity, void and of no effect," holding that the circuit court did not err.In this third iteration of appeals involving the issuance of the license Gulfside Casino Partnership (Gulfside) argued that the ARC's action was ultra vires because it was issued in violation of the clear language of amendment 100 to the Arkansas Constitution. The circuit court granted summary judgment for Gulfside, concluding that the casino license issued by the ARC jointly to CNB and Legends was an ultra vires action. The Supreme Court affirmed, holding that the circuit court did not err in its decision. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law
St. Vincent Medical Group v. Baldwin
The Supreme Court reversed the decision of the circuit court certifying a class action in the underlying lawsuit brought under the Patient Right-to-Know Addfct, Ark. Code Ann. 20-6-201 et seq., holding that the court abused its discretion in concluding that the predominance prerequisite of a class action had been satisfied.In his complaint, Plaintiff alleged that, after terminating his primary care physician, Dr. Anderson, St. Vincent Medical Group failed to provide Dr. Anderson with a list of his patients or to send them notice of his new location. The circuit court certified a class action. The Supreme Court reversed, holding that the circuit court erred in concluding that Plaintiff identified "a common course of conduct that affected all members of the class." View "St. Vincent Medical Group v. Baldwin" on Justia 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