Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the order of the circuit court dismissing Appellant's illegal exaction complaint with prejudice under Ark. R. Civ. P. 12(b)(6) for failure to allege facts upon which relief can be granted, holding that the circuit court erred.Appellant, a taxpayer, filed a complaint against Preferred Family Healthcare, Inc. (PFH), a provider of healthcare services, alleging that a significant portion of the funds PFH received from the State between 2010 and 2017 were acquired using unlawful means. The circuit court dismissed the complaint under Rule 12(b)(6) on the grounds that Appellant did not allege any wrongdoing on the State's part. The Supreme Court reversed, holding that a plaintiff is not required to allege wrongful state action in every case in order to state a claim for a "public funds" illegal exaction. View "Parsons v. Preferred Family Healthcare, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court admitting two 911 calls reporting a shooting and a dash cam video containing statements from an eyewitness during Defendant's criminal trial, holding that any error was harmless.After a jury trial, Defendant was convicted of first-degree murder, first-degree battery, and other crimes. After he was sentenced to life imprisonment plus fifteen years, Defendant filed a motion for a mistrial, which was deemed denied. The Supreme Court affirmed, holding (1) the circuit court properly ruled that the statements from the 911 calls were nontestimonial and thus admissible; (2) the circuit court erred in admitting the dash cam video, but the error was harmless beyond a reasonable doubt; and (3) Defendant's final two arguments were not preserved for appellate review. View "McNeil-Lewis v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court entering a declaratory judgment finding that the death benefit of a term life insurance policy owned by Dr. James Rocconi was payable to his children and not to Teresa James, Rocconi's ex-wife, holding that James was not entitled to relief on her allegations of error.After Rocconi died, his children and the executor of his estate brought a declaratory judgment action asking the circuit court to find that they were the beneficiaries of Rocconi's life insurance policy. James counterclaimed, seeking a declaratory judgment that the policy provided for payment of the death benefit to her. The circuit court entered judgment for Rocconi's children and executor. The Supreme Court affirmed, holding that James was not entitled to relief on her allegations of error. View "James v. Mounts" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellants' complaint alleging that the Arkansas Medical Marijuana Commission had granted a marijuana cultivation license to a corporate entity that had been dissolved, holding that the circuit court correctly dismissed this appeal on the merits.Appellants, existing cultivation license holders, challenged the Commission's decision to allegedly grant a license to a dissolved corporate entity, arguing that the circuit court erred by holding that it lacked subject-matter jurisdiction and wrongly held that Appellants lacked standing. The Supreme Court reversed, holding that the circuit court (1) erred by not finding that it lacked subject-matter jurisdiction and that Appellants lacked standing; but (2) properly dismissed the complaint because it failed to allege facts sufficient to mount the State's sovereign immunity defense. View "Osage Creek Cultivation, LLC v. Ark. Dep't of Finance & Administration" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting summary judgment in favor of Plaintiffs on their illegal-exaction claim related to Amendment 101 to the Arkansas Constitution, holding that the circuit court erred in its interpretation of Amendment 101.Plaintiffs brought this action against State Defendants raising claims related to tax revenue from both Amendment 91 and Amendment 101. The circuit court granted summary judgment in favor of State Defendants on the Amendment 91 illegal-exaction claim and in favor of Plaintiffs on their Amendment 101 claim. The Supreme Court reversed the circuit court's ruling pertaining to Amendment 101, holding that the circuit court erred in its interpretation of Amendment 101 to the Arkansas Constitution. View "Gibson v. Little Rock Downtown Neighborhood Ass'n" on Justia Law

The Supreme Court reversed the judgment of the circuit court convicting Appellant of first-degree murder and other crimes and sentencing him to an aggregate term of two life sentences plus 835 years' imprisonment, holding that the State failed to demonstrate that Appellant was brought to trial within the twelve-month period required by Ark. R. Crim. P. 28.1(b).At issue on appeal was whether Appellant's constitutional right to a speedy trial, as embodied in Ark. R. Crim. P. 28.1, was violated when the State failed to bring him to trial within twelve months of the date of his arrest. The Supreme Court concluded that Appellant's right was indeed violated because he was held for a total of 405 days during which the speedy trial was not tolled, a total that exceeded the requisite 365-day period. View "Parker v. State" on Justia Law

In this class action, the Supreme Court reversed the circuit court's judgment that certain sanitation fees constituted an illegal exaction and that the City of Fort Smith was unjustly enriched because the class paid money expecting to receive recycling services, holding that the circuit court clearly erred.Plaintiff, on behalf of the citizens and taxpayers of Fort Smith (class), brought this action against the City after discovering that Fort Smith was dumping almost all of its recyclables in a landfill, claiming that Fort Smith's collection of monthly sanitation charges, including recycling fees, was an illegal exaction and that the City had been unjustly enriched. The Supreme Court reversed and dismissed the action, holding (1) because Fort Smith used the sanitation fee to collect and dispose of sanitation, the circuit court's finding that the fee was an illegal exaction was clearly erroneous; and (2) the damages evidence Plaintiff presented was not a valid measure of restitution. View "City of Fort Smith v. Merriott" on Justia Law

The Supreme Court affirmed the order of the trial court denying Petitioner's pro se petition for postconviction relief alleging that his sentence was illegal pursuant to Ark. Code Ann. 16-90-111, holding that none of Petitioner's allegations established that his sentence was facially illegal.After a jury trial, Petitioner was convicted of capital murder, aggravated robbery, theft of property, and fleeing and was sentenced to to term of life imprisonment without parole. In his petition for postconviction relief, Petitioner made a series of claims regarding trial counsel and a claim of judicial bias. The Supreme Court affirmed the denial of the petition, holding that the trial court properly denied Petitioner's postconviction claims. View "Jefferson v. State" on Justia Law

The Supreme Court affirmed the decision of the trial court finding Appellant's pro se petition to correct an illegal sentence was both untimely and without merit, holding that the court did not err in denying the petition.Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. Twenty-four years after the mandate issued affirming Appellant's conviction, Appellant filed his petition to correct an illegal sentence. The trial court denied the petition, finding it to be both untimely and without merit. The Supreme Court affirmed, holding that twenty-four years exceeded the time to challenge how Appellant's sentences were imposed. View "Hussey v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying and dismissing Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not err in dismissing the petition.Appellant was convicted of first-degree felony murder and other crimes and sentenced as a habitual offender to an aggregate term of life imprisonment. Appellant later brought his petition for postconviction relief asserting that his trial counsel was ineffective in several respects. The trial court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate that his counsel provided ineffective assistance during trial. View "Price v. State" on Justia Law