Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed Appellant’s appeal from the denial of multiple pro se motions he filed in connection with a pro se civil-rights action he filed in the circuit court pursuant to 42 U.S.C. 1983, which rendered his two petitions for writ of certiorari, two amended petitions for certiorari, and multiple motions connected with the appeal moot.Appellant filed a complaint alleging that Appellees violated his civil rights. In addition to his civil complaint, Appellant filed multiple motions. The circuit court denied the motions and other pleadings on the basis that Appellant had failed to provide proof of service with respect to the complaint and the related pleadings. The Supreme Court dismissed Appellant’s appeal for lack of appellate jurisdiction because there was no final order on the merits. View "Nooner v. Kelley" on Justia Law

The Supreme Court dismissed the State’s appeal from the circuit court’s use of three nonmodel jury instructions at Appellee’s resentencing hearing, holding that the State failed to demonstrate that the appeal involved the correct and uniform administration of the law or that this was a proper State appeal.Appellee was resentenced after his life sentence was vacated for failure to comport with Miller v. Alabama, 467 U.S. 460 (2012). During the resentencing hearing, the circuit court instructed the jury with three nonmodel instructions based upon the Miller decision. The jury returned a sentence of forty years’ imprisonment, and the circuit court entered an order reducing Appellee’s sentence accordingly. The State appealed, arguing that the use of the nonmodel jury instruction was error. The Supreme Court dismissed the appeal, holding that this was not a proper State appeal. View "State v. Lasley" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Appellant’s petition for writ of habeas corpus in which he alleged that his sentence was illegally enhanced pursuant to Ark. Code Ann. 5-64-408. The court held (1) the circuit court did not err in denying Appellant’s request for default judgment; (2) Appellant’s allegations failed to establish probable cause that the writ should issue; (3) the circuit court did not lack jurisdiction to sentence Appellant utilizing the enhancement in section 5-64-408; and (4) the circuit court did not err by failing to have an evidentiary hearing on the matter. View "Darrough v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion for temporary restraining order (TRO) in favor of Appellees, who sought a declaratory judgment challenging the validity of the Arkansas Department of Human Services’ (DHS) new Resource Utilization Groups system rule. Appellees, low-income individuals with profound physical disabilities who received services through a program called Attendant Care, alleged that the switch from nurses’ assessments to to a computer algorithm reduced their attendant care hours by an average of forty-three percent and that such a reduction would be insufficient to meet their care needs. The circuit court concluded that Appellees demonstrated a likelihood of success on the merits and temporarily enjoined DHS from reducing their attendant-care hours. The Supreme Court affirmed, holding (1) the circuit court properly found irreparable harm in this case; (2) the circuit court did not abuse its discretion in finding that Appellees demonstrated a likelihood of success on the merits; and (3) Appellees were not required to exhaust their administrative remedies before seeking a declaratory order from the court. View "Arkansas Department of Human Services v. Ledgerwood" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court’s order requiring the Arkansas Department of Correction (ADC) to provide Steven Shults with the pharmaceutical package inserts and labels for its supply of midazolam, one of the drugs in the State’s execution protocol.Shults filed a complaint against the ADC after it refused to provide him with public records pertaining to the State’s supply of midazolam pursuant to his Arkansas Freedom of Information Act request. The ADC refused to disclose the package inserts or labels for the midazolam, arguing that these documents could be used to identify the sellers or suppliers of the drug in violation of the Method of Execution Act (MEA), Ark. Code Ann. 5-4-617. On appeal, the Supreme Court held (1) the circuit court correctly determined that the identity of drug manufacturers is not protected under the confidentiality provisions of section 5-4-617; but (2) the circuit court erred in requiring disclosure of the unredacted records, as certain information was confidential under section 5-4-617(j). The court remanded the case for the circuit court to determine which information must be redacted on the midazolam labels and/or package inserts at issue. View "Arkansas Department of Correction v. Shults" on Justia Law

The Supreme Court dismissed the State’s interlocutory appeal from the circuit court’s order granting Defendant’s motion to suppress. On appeal, the State argued that the circuit court erred (1) by interpreting Ark. R. Crim. P. 2.2 to invalidate the encounter between Defendant and the arresting officer, and (2) in concluding that the officer’s actions constituted a seizure. The Supreme Court held that this case was not properly before it under Ark. R. App. P.-Crim. 3 where this was a case involving the trial court’s consideration of the particular facts of the case and its determination that those facts did not provide reasonable suspicion for an investigatory stop under rule 3.1. View "State v. McWilliams" on Justia Law

In this case, one of three companion cases, Appellant appealed from sentencing orders entered after the original judgments of conviction, entered in 1978, were remanded in 2014 for resentencing. At issue in this appeal was whether the circuit court erred in denying Appellant’s request to run all of the sentences imposed on him on resentencing concurrent to each other. The Supreme Court affirmed, holding that the issue that Appellant raised on appeal did not directly relate to the case before the court, and therefore, there was no allegation of error in this case. View "Pennington v. State" on Justia Law

The circuit court committed a manifest abuse of discretion in ruling that testimony regarding the victim’s prior sexual conduct with a third party would be admissible pursuant to the rape-shield statute, Ark. Code Ann. 16-42-101(c), and Ark. R. Evid. 411(c)(2)(C) where Defendant was charged with raping the victim while she was physically helpless.Defendant was charged with rape in violation of Ark. Code Ann. 5-14-103(a)(2)(A), which provides that a person commits rape if he engages in sexual intercourse or deviate sexual activity with another person who is incapable of consent because that person is physically helpless. Before trial, the circuit court ruled that evidence of the victim’s sexual conduct from the day prior to the alleged rape would be admissible at Defendant’s trial as part of the res gestate of the case and to show the relationship between the parties. The Supreme Court reversed on interlocutory appeal, holding that the victim’s sexual conduct was not relevant or admissible under the rape-shield statute to show either the res gestate of the charged offense or the relationship between the parties. View "State v. Cossio" on Justia Law

In this case, one of three companion cases, Appellant appealed from sentencing orders entered after the original judgments of conviction, entered in 1978, were remanded in 2014 for resentencing. The Supreme Court affirmed, holding that, contrary to Appellant’s arguments on appeal, the circuit court had the authority to order that the sentences in one of the cases run consecutively to the sentences in the other two cases. Specifically, the court held (1) the trial court was permitted in 1978 to run Appellant’s sentences consecutively; and (2) as it was permissible in 1978 to sentence Appellant to the term of years imposed on resentencing and to run the sentences as ordered, the trial court did not exceed its jurisdiction in imposing Appellant’s sentence. View "Pennington v. State" on Justia Law

The Supreme Court affirmed Appellant’s convictions for aggravated robbery and capital murder. On appeal, Appellant argued that the circuit court erred in denying his motions for directed verdict and abused its discretion by admitting into evidence gruesome and inflammatory photographs of the victim’s body. The Supreme Court held (1) there was sufficient evidence from which the jury could conclude that Appellant was an accomplice to the crimes, and therefore, the circuit court did not err in denying Appellant’s motions for directed verdict; and (2) the circuit court did not abuse its discretion in admitting photographs of the victim’s body. View "Williams v. State" on Justia Law