Justia Arkansas Supreme Court Opinion Summaries

Appellant appealed his convictions of capital murder and kidnapping, arguing that the circuit court erred in denying his motions to suppress on five separate grounds. The State cross-appealed, arguing that the circuit court erred in granting Appellant’s motion to suppress evidence seized pursuant to two search warrants. The Supreme Court affirmed the denial of Appellant’s motions to suppress and dismissed the State's cross-appeal, holding (1) with regard to some of Appellant’s motions to suppress, the circuit court did not err in denying the motions, and with regarding to the remaining motions the court was precluded from addressing Appellant’s arguments; and (2) the State’s cross-appeal was untimely. View "Lewis v. State" on Justia Law

Appellant was convicted of residential burglary and sentenced to probation. Thereafter, Appellant was convicted of residential burglary and sentenced to a suspended imposition of sentence. Appellant was then convicted of aggravated robbery with a firearm enhancement. The trial court revoked the probation and suspended imposition of sentence and sentenced Appellant to life imprisonment and additional terms of imprisonment on each revocation. The Supreme Court affirmed the revocations but reversed and remanded as to the aggravated-robbery conviction and the firearm enhancement, holding (1) the trial court erred in denying Appellant’s motion to suppress his statement to a detective, and the error was not harmless; and (2) Appellant raised no allegation of error as to the revocations, and thus they stand. View "Coleman v. State" on Justia Law

The circuit court imposed upon the City of Little Rock a fine for violations of Ark. R. Civ. P. 11 and found the City in contempt for failure to timely pay the time. The City appealed, arguing that the imposition of Rule 11 sanctions and the finding of contempt constituted a plain, manifest, and gross abuse of discretion. The Supreme Court affirmed in part and dismissed in part, holding (1) the City’s payment of the penalty rendered an appeal from the circuit’s court’s order imposing the fine moot; and (2) the finding of contempt was not clearly against the preponderance of the evidence. View "City of Little Rock v. Circuit Court of Pulaski County" on Justia Law

Hence forth, all briefed cases submitted to the court of appeals must be disposed of by full, written majority opinions. Thus, In re Memorandum Opinions, 700 S.W.2d 63 (Ark. Ct. App. 1985), in which the court of appeals promulgated its memorandum-opinion policy, is hereby overruled.In this workers’ compensation case, Appellants filed a petition asking the Supreme Court to review an opinion handed down by the court of appeals. Neither the full commission nor the court of appeals issued a formal opinion, as the full commission adopted the administrative law judge’s findings and the court of appeals issued a memorandum opinion. The Supreme Court vacated the court of appeals’s opinion and remanded the case to that court to properly analyze this case, as the opinion provided no meaningful analysis. Because Arkansas Supreme Court Rule 5-2(e) has previously allowed the court of appeals to issue memorandum opinions, the rule is hereby amended to state that opinions of the court of appeals shall only be in conventional form. View "Brookshire Grocery Co. v. Morgan" on Justia Law

Appellant pleaded guilty to murder in the first degree and was sentenced to 480 months in prison. Appellant later filed a petition for writ of habeas corpus seeking release from custody. The circuit court dismissed the petition because Appellant did not state a basis for issuance of the writ. Appellant appealed. The State filed a motion to dismiss the appeal on the grounds that Appellant had failed to submit a brief or otherwise take any action to pursue the appeal. The Supreme Court granted the motion, holding that the circuit court did not err in dismissing Appellant’s habeas petition because Appellant did not establish that the trial court lacked jurisdiction in his case or that the commitment was invalid on its face. View "Barber v. Kelley" on Justia Law

In this wrongful termination case, Peggy Cryer, who was sued individually and in her official capacity as executive secretary of the Arkansas State Medical Board, was entitled to statutory immunity on some, but not all, of Plaintiff's claims.Kristi Byers was terminated from her employment with the Board for allegedly not using leave time on days that she did not come to work. Byers filed suit against the Board and Cryer for wrongful termination, alleging race discrimination and retaliation under the Arkansas Civil Rights Act (ACRA) and seeking damages and injunctive relief. The circuit court denied Defendants’ motion for summary judgment on immunity grounds, concluding that Defendants were not entitled to sovereign immunity and Cryer was not entitled to statutory immunity. The Supreme Court affirmed in part and reversed in part, holding that Cryer was entitled to statutory immunity on Byers’s individual-capacity race discrimination and retaliation claims under the ACRA but statutory immunity did not bar Byers’s federal civil rights claims against Cryer in her individual capacity. Remanded. View "Arkansas State Medical Board v. Byers" on Justia Law

In 2006, Appellant pleaded guilty to first-degree battery and other offenses. In 2016, Appellant filed a second amended petition seeking coram nobis relief. The trial court denied relief, noting that it had found Appellant’s first coram nobis petition untimely and that the second petition “would be no timelier than the first.” On appeal, Appellant argued that he had a valid excuse for his delay because he did not become aware of an exculpatory statement allegedly withheld by the State until the time immediately before he filed his first petition for coram nobis relief. The Supreme Court reversed, holding (1) the trial court erred in limiting its examination of the due diligence requirement to the length of time from Appellant’s imposition of sentence without giving due consideration to Appellant’s claims regarding when he became aware of the allegedly exculpatory statement; and (2) Appellant stated sufficient allegations that may satisfy the due diligence requirement, and factual determinations were essential in deciding whether the writ should be granted. View "Scott v. State" on Justia Law

In 2014, Appellant, who was not a naturalized citizen of the United States, entered a negotiated change of plea to possession with the purpose to deliver methamphetamine. The circuit court accepted the plea and sentenced Appellant to two years and an additional term of three years’ suspended imposition of sentence (SIS). In 2015, Appellant filed a petition for writ of habeas corpus alleging that he was not provided with warnings regarding immigration and deportation pursuant to Padilla v. Kentucky, 559 U.S. 356 (2010). The circuit court denied the petition. The Supreme Court affirmed, holding that the court lacked jurisdiction to grant habeas relief because, despite Appellant’s SIS sentence, Appellant was not in custody as defined by this state’s laws. View "Rangel v. State" on Justia Law

Petitioner, who was convicted on charges of kidnapping, rape, and murder, filed a pro se petition for scientific testing under Act 1780 of 2001 Acts of Arkansas. Petitioner filed a petition for leave to proceed in forma pauperis on the Act 1780 petition on the same date. The circuit court denied the Act 1780 habeas petition and found that the in forma pauperis petition was denied “due to venue issues.” Petitioner filed a notice of appeal. The clerk, however, declined to file the record on the basis that it was not tendered within ninety days of the notice of appeal. Petitioner then filed a pro se motion for belated appeal in the Supreme Court. The court treated Petitioner’s motion as one for rule on clerk and denied the motion, holding that Petitioner could not prevail on appeal because he failed to state a basis on which the trial court could have ordered scientific testing under the statutes. View "Marshall v. State" on Justia Law

Appellant, who was incarcerated at a unit of the Arkansas Department of Correction located in Lee County for committing the crime of rape, filed a pro se petition for writ of habeas corpus in the Lincoln County Circuit Court. The circuit court dismissed the petition. Appellant sought to appeal. Now before the court was Appellant’s motion for extension of time to file brief. The Supreme Court dismissed Appellant’s appeal, holding that Lincoln County Circuit Court was without jurisdiction to dictate Appellant’s release because Appellant was not currently in that county. The dismissal of the appeal rendered the motion moot. View "Williams v. Kelley" on Justia Law