Justia Arkansas Supreme Court Opinion Summaries

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After a jury trial, Petitioner was found guilty of residential burglary and rape. Petitioner was sentenced as a habitual offender to 900 months’ imprisonment. The court of appeals affirmed. Petitioner later filed this, his third pro se petition asking the Supreme Court to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. The Supreme Court denied the writ, holding (1) in Petitioner’s present petition, he failed to allege any facts sufficient to distinguish his current claims from his two prior attempts seeking coram-nobis relief, excepting one claim; and (2) regarding that claim, the claim was conclusory in nature and failed to establish that there was some error. View "Noble v. State" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of raping a mentally handicapped sixteen-year-old girl. Appellant was sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed in the trial court a pro se petition under Ark. R. Crim. P. 37.1 and motion for error coram nobis. On appeal, Appellant argued that his postconviction petition was not untimely, contrary to the trial court’s holding, because the postmark on his petition indicated that it was mailed well before the due date and that the file mark was a clerical error. The Supreme Court affirmed in part and reversed in part, holding (1) under the facts and circumstances of this case, Appellant’s Rule 37.1 and coram-nobis petition should have been filed prior to the filing deadline, and the matter is remanded for the circuit court to file-mark Appellant’s Rule 37.1 petition with the appropriate date; and (2) the trial court properly dismissed Appellant’s coram-nobis petition. View "McClinton v. State" on Justia Law

Posted in: Criminal Law
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Guy Hendrix, the decedent in this case, worked for Alcoa Inc. for nearly thirty years. After he retired, Hendrix filed a claim against Alcoa for workers’ compensation benefits, alleging that he was exposed to asbestos during the course of his employment, leading to his diagnosis of an asbestos-related cancer. An administrative law judge found that the claim was time-barred because it was not filed within three years of his last date of the injurious exposure. After Hendrix died, his estate initiated this wrongful-death and survival action against Alcoa. Alcoa moved to dismiss the claims, asserting that the circuit court lacked jurisdiction because the claims fell within the exclusive-remedy provision of the Workers’ Compensation Act. The circuit court agreed and dismissed the claims against Alcoa with prejudice. The estate appealed, arguing that because the statute of repose extinguished Hendrix’s remedy under the Act before it accrued, the exclusive-remedy provision no longer applied. The Supreme Court affirmed, holding that the claim falls within the coverage formula of the Act, even though Hendrix was ultimately denied recovery on the ground that the claim was time-barred. View "Hendrix v. Alcoa Inc." on Justia Law

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Appellant pleaded guilty to second-degree sexual assault and was sentenced to 144 months’ imprisonment. Thereafter, Appellant filed an untimely petition for postconviction relief under Ark. R. Crim. P. 37.1. The circuit court denied the petition on the ground that it was untimely. Appellant lodged an appeal in the Supreme Court. Now before the Court were Appellant’s pro se motions requesting files generated by his trial counsel and also counsel that Appellant alleged represented him in matters involving the Arkansas Department of Human Services. In violation of Ark. R. Crim. P. 19(b), counsel failed to file responses with the Supreme Court. Therefore, the Court directed trial counsel and counsel at issue to file a response with the Court within twenty days from the date of this opinion. View "Geatches v. State" on Justia Law

Posted in: Criminal Law
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Christopher Foster and Leah Foster were divorced pursuant to a divorce decree that awarded Leah primary custody of the parties’ three children, with Christopher receiving visitation. The decree approved the parties’ settlement agreement regarding the disposition of the marital assets. The circuit court also found that an award of rehabilitative alimony was appropriate. The court further awarded Leah attorney’s fees. The Supreme Court affirmed, holding (1) the circuit court did not err in its interpretation of Ark. Code ann. 9-12-312(b) or in its finding that Leah was entitled to rehabilitative alimony under the facts of this case; (2) the circuit court did not abuse its discretion it setting the amount and the duration of the alimony award; and (3) the circuit court did not abuse its discretion in awarding attorney’s fees and litigation-related expenses to Leah. View "Foster v. Foster" on Justia Law

Posted in: Family Law
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After a jury trial, Appellant was found guilty of three counts of delivery of cocaine and one count of delivery of a counterfeit substance. Appellant was sentenced to 552 months’ imprisonment. The court of appeals affirmed. In separate proceedings later that same year, Appellant was convicted of fleeing apprehension and leaving the scene of a personal injury accident. Appellant was sentenced to 360 months’ imprisonment, to run consecutively to the sentences imposed in the earlier conviction. Appellant filed pro se petitions for postconviction relief as to both judgments. The trial court consolidated the proceedings and denied both petitions. The Supreme Court affirmed, holding that the trial court did not err or clearly err in denying postconviction relief on Appellant’s claims. View "Flemons v. State" on Justia Law

Posted in: Criminal Law
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CACH, LLC filed a complaint against William Echols alleging that Echols breached his contract with a bank when he defaulted on his obligation to pay for charges incurred on a credit card and that, as current owner of the account, CACH was entitled to payment of the balance due on the credit card. Echols filed a class action counterclaim alleging that CACH violated the Arkansas Deceptive Trade Practices Act and the common law when it demanded payment from and filed suit against Echols and other Arkansas residents. The circuit court entered an order granting class certification. The Supreme Court affirmed, holding that the circuit court did not err in granting class certification. View "CACH, LLC v. Echols" on Justia Law

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After a jury trial, Petitioner was found guilty of several drug offenses. Petitioner was sentenced to a term of life imprisonment on the charge of possession of cocaine with intent to deliver, to be served consecutively to his remaining sentences. Now before the Supreme Court was Petitioner’s pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in the case. As grounds for the writ, Petitioner asserted that the State violated his right to due process during trial pursuant to Brady v. Maryland. The Supreme Court denied the petition, holding that Petitioner failed to demonstrate a Brady violation that warranted issuance of a writ of error coram nobis. View "Carter v. State" on Justia Law

Posted in: Criminal Law
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After C.E. was born, the circuit court ordered C.E. to be removed from his mother and placed in the custody of the Arkansas Department of Human Services (ADHS). The court subsequently entered an adjudication order finding C.E. dependent-neglected. The court ordered a home study of C.E.’s paternal uncle and his wife (together, the Ellises). C.E.’s foster parents (together, the Coles) sought to intervene in the dependency-neglect case, stating that they wanted to adopt C.E. C.E.’s father urged the circuit court to consider and approve the home study and place C.E. with the Ellises. The circuit court ordered that C.E. was to remain in his foster home with the Coles and changed the permanency goal to adoption. The Supreme Court reversed, holding that, upon receipt of the satisfactory home study, the circuit court erred by failing to conduct the mandatory review hearing and apply the statutory preference for relative placement to the Ellises. Remanded. View "Ellis v. Arkansas Department of Human Services" on Justia Law

Posted in: Family Law
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After a jury trial, Appellant was convicted of one count of capital felony murder and sentenced to death. The Supreme Court affirmed, holding that the circuit court (1) did not violate Appellant’s right to a fair and impartial jury trial by allowing Appellant’s entire “pen pack” to be submitted to the jury; (2) did not violate Appellant’s due process rights by limiting defense counsel's questions to potential jurors; (3) did not improperly remove jurors for cause; (4) did not err in granting the State’s motion for a mental-health evaluation of Appellant; (5) did not err in refusing to allow certain jury instructions proffered by the defense; (6) did not err in denying Appellant’s proffered jury instruction regarding “lingering doubt” as a mitigating circumstance; and (7) did not err in refusing to allow Appellant to introduce as a mitigating circumstance that Appellant had a calming influence on others while in custody. View "Gay v. State" on Justia Law

Posted in: Criminal Law