Justia Arkansas Supreme Court Opinion Summaries

After a jury trial, Petitioner was found guilty of two counts of rape. Petitioner was sentenced to two consecutive terms of twenty years’ imprisonment. Now before the Supreme Court was Petitioner’s fourth pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis. In his petition, Petitioner raised allegations not raised in the first three petitions, including claims that his judgment of conviction was illegally rendered because of an invalid arrest warrant and an insufficient information. The Supreme Court denied the petition, holding that Petitioner’s allegations were not cognizable in a coram-nobis proceeding and were otherwise without merit. View "Smith v. State" on Justia Law

Appellant filed a request for documents related to his criminal case under the Freedom of Information Act. Appellee, the custodian of records for the Arkansas State Crime Laboratory, denied the request on the grounds that Appellant was an inmate incarcerated in the Arkansas Department of Correction. Thereafter, Appellant sought a hearing before the circuit court and filed a petition to proceed in forma pauperis. The circuit court initially granted the petition but later revoked Appellant’s pauper status and dismissed the case without prejudice, finding that three federal lawsuits should be counted as strikes under Ark. Code Ann. 16-68-607. The Supreme Court reversed, holding that the circuit court erred in counting as strikes cases Appellant filed in federal district court. Remanded. View "Hill v. Gallagher" on Justia Law

This case arose from a dispute between George Stokes and his son, Mason Stokes, over the ownership of farmland in Chicot County. Mason filed a petition to quiet title to the farmland. The circuit court ruled that Mason and George each owned an undivided one-half interest in the farmland as tenants in common and authorized distribution of one-half of the crop income to Mason. The court then awarded Mason attorney’s fees. The Supreme Court affirmed in part and reversed in part, holding that the circuit court (1) did not deny George’s constitutional right to trial by jury by adjudicating the equitable claims before the legal claims; (2) did not err by validating a 1999 warranty deed; (3) did not err in granting summary judgment and in ruling that a 2009 quitclaim deed was void; but (4) erred by awarding attorney’s fees to Mason. View "Stokes v. Stokes" on Justia Law

Petitioner pleaded guilty to a charge of possession of firearms by certain persons. Petitioner later filed a timely pro se petition pursuant to Ark. R. Crim. P. 37.1 seeking to challenge the judgment. The trial court denied the petition after a hearing. When the record on appeal was tendered to the Supreme Court, the clerk declined to lodge it because it was not received within the required time. Petitioner subsequently filed a motion for rule on clerk seeking permission to proceed with the appeal. The Supreme Court denied the motion, holding that Petitioner failed to demonstrate that he filed a motion for extension of time within the requisite period of time and failed to demonstrate good cause for his failure to comply with the rules of procedure. View "Smith v. State" on Justia Law

After a jury trial, Appellant was found guilty of second-degree battery and of being a felon in possession of a firearm. Appellant’s convictions and sentences were affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, alleging ineffective assistance of counsel. The trial court ultimately concluded that Appellant’s claims were not supported by the record. The Supreme Court affirmed, holding (1) the trial court did not clearly err when it denied Appellant’s petition without conducting an evidentiary hearing; and (2) the trial court did not clearly err in concluding that counsel did not provide ineffective assistance. View "Russell v. State" on Justia Law

Petitioner was convicted of first-degree battery and second-degree battery and sentenced to an aggregate sentence of 264 months’ imprisonment. The convictions were affirmed on appeal. Now before the Supreme Court was Petitioner’s second pro se application to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and Petitioner’s motion for permission to file a response to the State’s response. The Supreme Court dismissed the petition and declared the motion moot, holding that Petitioner did not establish a basis for issuance of the writ in his first coram-nobis petition, and his reassertion of essentially the same claims in the instant petition was a misuse of the remedy. View "Moten v. State" on Justia Law

Columbia Insurance Group, Inc. and Columbia Mutual Insurance Co. (collectively, Columbia) filed a complaint for declaratory judgment to determine Columbia’s obligations under the Commercial General Liability Insurance Policy (CGL policy) issued to its insureds, Arkansas Infrastructure, Inc. and David Barron (collectively, AII). Specifically, Columbia sought a declaration that it had no duty to defend or indemnify AII with respect to claims brought against AII in state court by Homeowners. A federal district court concluded that Columbia had an obligation to defend AII in the underlying suit. The district court then certified two questions of law to the Supreme Court, asking (1) whether faulty workmanship resulting in property damage to the work or work product of a third party constitutes an “occurrence," and (2) if so, and an action is brought in contract for property damage to the work or work product of a third party, whether any exclusion in the policy bars coverage for this property damage. The Supreme Court (1) reaffirmed the Court’s previous position that a CGL policy does not extend basic coverage for a claim of breach of contract; and (2) held that because there is no coverage under the policy in this case, the certified questions are moot. View "Columbia Ins. Group v. Cenark Project Mgmt. Servs., Inc." on Justia Law

Daniel Wren requested from The Arkansas State Police (ASP) unredacted access to certain accident reports under the Freedom of Information Act (FOIA). ASP contended that its policy of redacting personal information from accident reports was permitted under FOIA because disclosure is prohibited by the federal Driver’s Privacy Protection Act (DPPA). The circuit court ruled in favor of Wren and enjoined the policy of the ASP regarding redactions of accident reports. The Supreme Court Affirmed, holding that the DPPA does not prohibit disclosure of personal information in accident reports, which are public records within the meaning of FOIA. View "Ark. State Police v. Wren" on Justia Law

Defendant was charged with rape and possession of child pornography. Defendant moved to suppress ten pornographic images of children discovered during a search of his home pursuant to search warrants. The circuit court suppressed the evidence, finding that the absence of time references to when the alleged criminal conduct occurred in the affidavits supporting the application for the warrants made the warrants invalid. The State filed this interlocutory appeal, arguing that “the time of the inculpatory information is not an essential element of probable cause” and that the evidence was admissible under the good-faith exception to the exclusionary rule. The Supreme Court dismissed the appeal, holding that this was not a proper State appeal. View "State v. Sprenger" on Justia Law

Appellants sued Appellees in circuit court, alleging causes of action for civil conspiracy, intentional interference with a contractual relationship or business expectancy, fraud and fraudulent inducement, and violation of the Arkansas Deceptive Trade Practices Act (ADTPA). Appellants later voluntarily dismissed their intentional interference and ADPTA claims. The trial court granted summary judgment in favor of Appellees on the remaining claims. Appellants appealed, arguing that there remained genuine issues of material fact that precluded summary judgment in this case. The Supreme Court affirmed, holding that Appellees failed to present sufficient proof to raise a question of fact with regard to the claims before the trial court on summary judgment. View "Muccio v. Hunt" on Justia Law