Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the trial court’s denial of Appellant’s pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not provide sufficient written findings to demonstrate that Appellant was not entitled to relief on his ineffective assistance claims. The trial court denied relief without conducting an evidentiary hearing. The Court remanded to the trial court with directions to conduct a postconviction hearing limited to the two claims of ineffective assistance of counsel preserved by Appellant in this appeal. View "Collins v. State" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the circuit court’s denial of his pro se petition for a writ of habeas corpus and for a writ of audita querela, which rendered moot his pro se motions related to the appeal. In the petition, Appellant argued that he was actually innocent and was entitled to habeas and audita querela relief based on Bailey v. United States, 516 U.S. 137 (1995). The circuit court denied the petition based on the lack of jurisdiction to hear either claim. The Supreme Court affirmed, holding that it was clear from a review of the record that the circuit court did not have jurisdiction to address the claims for postconviction relief under either of the two interchangeable remedies. View "Hill v. Kelley" on Justia Law

The Supreme Court dismissed Appellant’s appeal from the denial of his petition filed under Ark. R. Crim. P. 37.1, which mooted Appellant’s motions in which he sought permission from the Supreme Court to include in the addendum of his brief a portion of the trial court’s docket listing.On remand from the Supreme Court, the trial court considered Appellant’s claims in the petition for Rule 37 relief. The court then denied and dismissed the petition. The Supreme Court affirmed, holding that the trial court correctly determined that Appellant was not entitled to relief on his allegations of trial error or ineffective assistance regarding those claims and that his direct challenge to the sufficiency of the evidence was not cognizable in this Rule 37 proceeding. View "McClinton v. State" on Justia Law

The Supreme Court treated Petitioner’s pro se motion for belated appeal and rule on clerk seeking to proceed with a belated appeal of the judgment convicting him of sexual assault in the second degree as a motion for belated appeal and remanded the matter to the trial court for an evidentiary hearing, holding that the proper disposition of the motion for belated appeal in this case will require findings of fact. Petitioner, who was convicted of sexual assault in the second degree, argued that his trial counsel failed to pursue an appeal on his behalf. Because the proper disposition of Petitioner’s motion for belated appeal will require findings of fact, the Supreme Court remanded this matter to the trial court for an evidentiary hearing. View "Beene v. State" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s request to proceed in forma pauperis with a petition for a writ of habeas corpus, which mooted the motion before the Court in which Appellant sought an extension of time to file his brief.The habeas petition, Appellant sought to pursue as a pauper sought habeas relief based on new scientific evidence and alleged that his conviction should be dismissed because the trial court lacked jurisdiction. The circuit court denied the petition, finding that Appellant failed to allege facts that would support a colorable cause of action. The Supreme Court affirmed the denial of pauper status, holding that Appellant alleged no facts that would support issuance of the writ and failed to state a colorable cause of action. View "Muldrow v. Kelley" on Justia Law

In this interlocutory appeal, the Supreme Court reversed an order of the circuit court denying Defendant’s motion for judgment on the pleadings and dismissed Plaintiff’s complaint on the grounds that it was barred by the doctrine of sovereign immunity.In her complaint, Plaintiff alleged that Defendant, Arkansas Community Correction (ACC), terminated her in violation of the Arkansas Whistle-Blower Act (AWBA). Defendant moved for judgment on the pleadings on the grounds that it was an agency of the State and that the General Assembly could not validly waive the State’s sovereign immunity under the AWBA. The circuit court denied the motion. The Supreme Court reversed, holding that to the extent the legislature subjected the State to liability in the AWBA, it was prohibited by Ark. Const. art. V, 20. View "Arkansas Community Correction v. Barnes" on Justia Law

The Supreme Court affirmed in part and affirmed as modified in part the decision of the Arkansas Workers’ Compensation Commission awarding benefits to Employee for injuries that arose out of and in the course and scope of Employee’s employment with Employer.As pertinent to this appeal, the Commission found (1) Employee was entitled to a permanent anatomical-impairment rating of twenty-nine percent for his brain injury and twenty-four percent for his left-eye injury, both to the body as a whole; and (2) Employee was not entitled to benefits based on a permanent anatomical-impairment rating based on pain. Employer appealed, and Employee cross-appealed. The Supreme Court held (1) the Commission’s decision that Employee was entitled to a permanent anatomical-impairment rating of twenty-nine percent for his brain injury to the body as a whole for his brain injury was supported by substantial evidence; (2) the Commission’s finding of 100 percent impairment to Employee’s left eye was proper, but the award is modified to reflect that it is a scheduled injury; (3) the Commission’s decision denying twenty-four percent whole-body impairment rating for cranial nerve V and trigeminal nerve damage was supported by substantial evidence. View "Multi-Craft Contractors, Inc. v. Yousey" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant, after a jury trial, of aggravated residential burglary, aggravated assault on a family or household member, and first-degree terroristic threatening and sentencing him as a habitual offender to life imprisonment plus fifteen years and a $10,000 fine. The Court held (1) the circuit court did not err by denying Defendant’s requests to represent himself at trial; and (2) the circuit court did not conduct a proper inquiry when denying Defendant’s motion for mistrial based on a juror looking up something with his cell phone and sharing that information with other jurors during guilt-innocence phase deliberations, but there was no reasonable probability of prejudice to Defendant in this case. View "Finch v. State" on Justia Law

The Supreme Court reversed the circuit court’s order granting Defendants’ motion to dismiss Plaintiff’s refund action pursuant to Ark. R. Civ. P. 12(b)(8) based on the doctrine of res judicata, holding that res judicata did not bar Plaintiff’s suit.After receiving the Faulkner County Assessor’s valuation of its personal property, Plaintiff challenged the assessments. The Faulkner County Board of Equalization upheld the assessments, as did the Faulkner County Court. The circuit court dismissed Plaintiff’s valuation appeal for lack of subject matter jurisdiction. During the discovery process in the valuation appeal, Plaintiff learned of errors regarding the issues in the first complaint. Plaintiff then filed a claim in the Faulkner County Court for a refund of its 2012 ad valorem taxes under Ark. Code Ann. 26-35-901 based on an erroneous assessment of its personal property and on the taxation of its exempt intangible property. The county court dismissed the refund action under Ark. R. Civ. P. 12(b)(8) because the earlier case involved the same parties and arose out of the same occurrence. Plaintiff appealed. The circuit court dismissed the refund action, finding that the refund claims were precluded by res judicata. The Supreme Court reversed, holding that because the valuation appeal was dismissed for lack of subject-matter jurisdiction, there was no valid judgment in that case by a court with proper jurisdiction, and all of the required elements of claim preclusion were not satisfied. View "Desoto Gathering Co. v. Hill" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s pro se petition for writ of habeas corpus, holding that the circuit court did not abuse its discretion in finding that Appellant stated insufficient grounds for the writ.In his writ, Appellant alleged that there was insufficient evidence to support the enhancements to the sentences for prior convictions noted on the judgment of conviction and that he was not competent when the crimes were committed or to stand trial. The circuit court found that Appellant’s petition failed to set forth a basis for the writ. The Supreme Court affirmed, holding (1) the circuit court’s application of Philyaw v. Kelley, 477 S.W.3d 503 (Ark. 2015), was not in error; and (2) the trial court did not abuse its discretion in finding that the grounds in Appellant’s petition did not support the writ. View "Ratliff v. Kelley" on Justia Law