Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err.In his section 16-90-111 petition, Petitioner alleged that consecutive sentences imposed upon revocation of suspended sentences in eight separate cases were illegal. Ark. R. Crim. Code 37.2(c) required Petitioner to file a Ark. R. Crim. Code 37.1 petition challenging the revocation of his suspended sentences within sixty days of the mandates issued by the court of appeals in May and July 2016. Petitioner, however, filed his petition to correct an illegal sentence almost four years later, in February 2020. The circuit court denied and dismissed the petition because Rule 37.1 had superseded it, and Petitioner's petition was untimely. The Supreme Court affirmed, holding that Petitioner was not entitled to relief. View "Todd v. State" on Justia Law

The Supreme Court granted Petitioner's pro se petition for a writ of mandamus directing Honorable Quincy Ross, circuit judge, to issue an order acting on Petitioner's habeas petition within thirty days of the date of this opinion, holding that Petitioner was entitled to the writ.Petitioner pleaded guilty to theft of property and was sentenced to sixty months' imprisonment as a habitual offender. In his mandamus petition, Petitioner asserted that Judge Ross had failed timely to act on his petition for writ of habeas corpus. The Supreme Court granted the writ because Petitioner's habeas petition had been pending since 2021, no action had been taken, and the State's response offered no explanation for the extended delay. View "Davis v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition to correct an illegal sentence, holding that Petitioner failed to establish either that his sentence was illegal on its face or, at the time of sentence, that the sentencing court lacked subject-matter jurisdiction.Petitioner pleaded guilty to manslaughter and robbery and stipulated that he was a habitual offender. Petitioner was sentenced to sixty months in prison for manslaughter and 480 months for robbery, with his sentences to run consecutively. Petitioner later filed a petition for relief from an illegal sentence, which the circuit court denied. The Supreme Court affirmed, holding that Defendant's sentence fell within the maximum prescribed sentence and was legal on its face and that the circuit court did not clearly err in denying Petitioner's petition on all grounds. View "Harmon v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se motion to vacate and dismiss judgment and commitment order due to lack of jurisdiction filed under Ark. Code Ann. 16-90-111, holding that there was no error.In his motion, Appellant argued that the trial court lacked jurisdiction to convict him because he did not engage in the criminal conduct contemplated by Ark. Code Ann. 5-54-119 and because the elements of section 5-54-119 were not established. The Supreme Court affirmed the trial court's denial of the motion, holding that the trial court did not clearly err when it found that Appellant did not state a cause of action under section 16-90-111(a). View "Gonder v. State" on Justia Law

The Supreme Court reversed the order of the circuit court granting Defendant's motion to dismiss this tort action brought against an estate, holding that the statute of nonclaim, as opposed to the general three-year statute of limitations, governed Plaintiff's claims and that she timely filed her amended complaint pursuant to the applicable limitation period.Plaintiff filed an amended complaint against the special administrator overseeing the estate of the person with whom she was in an automobile accident. Defendant filed a motion to dismiss the complaint pursuant to Ark. R. Civ. P. 12(b)(6) on the grounds that it was barred by the applicable statute of limitations. The circuit court granted the motion. The Supreme Court reversed, holding that the circuit court erred in applying the general three-year statute of limitations in dismissing Plaintiff's amended complaint as untimely rather than applying the applicable limitation period set forth in the statute of nonclaim. View "Marcum v. Hodge" on Justia Law

The Supreme Court reversed the order of the circuit court granting a temporary restraining order (TRO) in favor of Plaintiffs in their lawsuit challenging the validity of the emergency clause in Act 237 of 2023 (the LEARNS Act), holding that the circuit court erred in granting Plaintiffs' motion for injunctive relief.After the LEARNS Act was signed into law Plaintiffs sought a TRO, asserting that they would suffer irreparable harm if Defendants continued to implement the Act despite an invalid emergency clause relating to the creation of transformation contracts. The circuit court granted the TRO until a scheduled hearing. The Supreme Court reversed and vacated the TRO, holding that Plaintiffs failed to meet their burden of providing irreparable harm. View "Ark. Dep't of Education v. Jackson" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting and sentencing Defendant for first-degree battery and failure to appear on a felony, holding that the circuit court did not abuse its discretion by denying Defendant's motion to substitute counsel and that there was substantial evidence to support Defendant's conviction for first-degree battery.After a three-day trial, the jury convicted Defendant of first-degree battery and failure to appear but acquitted him of second-degree battery. The Supreme Court affirmed, holding (1) because Defendant was indigent he was not entitled to the counsel of his choice, and therefore, the circuit court did not abuse its discretion in denying Defendant's motion to substitute counsel; and (2) the State introduced substantial evidence sufficient to support Defendant's conviction for first-degree battery. View "Mitchell v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court awarding attorneys' fees after a medical doctor sued and lost against a hospital following its revocation of the doctor's medical staff and surgical privileges, holding that the circuit court did not err or abuse its discretion.Doctor, a surgeon, sued Hospital after his termination stemming from allegations that Doctor provided care that fell short of standard surgical practice. After a remand, all of Doctor's claims were dismissed. Thereafter, the circuit court awarded Hospital attorneys' fees and costs. The Supreme Court affirmed, holding (1) the motion for attorneys' fees was timely filed; and (2) Doctor was not entitled to relief on his remaining allegations of error. View "Williams v. Baptist Health" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's legal malpractice complaint against Appellees, her attorneys, and finding that there were no facts in the complaint sufficient to toll the running of the statute of limitations based on fraudulent concealment, holding that there was no error.In the motion to dismiss, Appellees argued that Appellant's malpractice claim was barred by the applicable statute of limitations and should be dismissed. The circuit court granted the motion to dismiss based on the statute of limitations. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in dismissing the case and finding there were no facts contained in the complaint sufficient to toll the running of the statute of limitations based on fraudulent concealment. View "Nichols v. Gibson" on Justia Law

The Supreme Court denied a petition for a writ of certiorari or, in the alternative, a writ of prohibition, writ of mandamus or other supervisory writ, holding that the circuit court did not misinterpret the Arkansas Rules of Civil Procedure in the underlying discovery matter.Respondents filed a complaint against Monsanto Company alleging claims for design defect, failure to warn, negligence, breach of implied warranties, violation of the Arkansas Deceptive Trade Practices Act, and loss of consortium. After Respondents served Monsanto with a deposition notice Monsanto moved for a protective order arguing that the deposition was not permitted. The circuit court denied Monsanto's motion for protective order. Monsanto then brought this petition. The Supreme Court denied the petition, holding that Monsanto was seeking to control the circuit court's exercise of its discretion in this discovery matter and that mandamus will not lie for this purpose. View "Monsanto Co. v. Kilgore" on Justia Law