Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the ruling of the circuit court finding that the emergency clause contained within Act 237 of 2023 (the LEARNS Act) did not receive a separate roll-call vote as required under the Arkansas Constitution, rendering the clause procedurally invalid, holding that Arkansas General Assembly complied with Ark. Const. V, 1 when it enacted the LEARNS Act emergency clause.After the General Assembly passed the LEARNS Act the legislation was sent the Governor, who signed it into law. Appellees brought the underlying complaint seeking a declaration that the Act's emergency clause, under which certain provisions became effective on the date of the Governor's approval, was invalid. Upon remand, the circuit court declared the LEARNS Act emergency clause invalid because it did not receive a separate roll-call vote. The Supreme Court reversed, holding that the emergency clause was passed in compliance with article 5, section 1. View "Ark. Dep't of Education v. Jackson" on Justia Law

The Supreme Court denied a petition for writ of certiorari and/or prohibition requesting relief from the Court after the circuit court denied Petitioner's motions to dismiss the charges against him, holding that an extraordinary writ was not necessary in this case.Petitioner, who was charged with aggravated robbery and other charges, moved to dismiss the charges for a violation of his right to a speedy trial pursuant to Ark. R. Crim. P. 28.1, asserting that he was not brought to trial within twelve months from the date of his arrest. Petitioner also filed a motion to dismiss for lack of jurisdiction, alleging that the juvenile division retained exclusive jurisdiction. The circuit court denied both motions. The Supreme Court denied Petitioner's ensuing petition for writ of certiorari and/or prohibition, holding that the circuit court did not err in denying Petitioner's motions to dismiss for lack of jurisdiction and for violation of his speedy-trial rights. View "Tilson v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition and amended petition for declaratory judgment and writ of mandamus wherein Defendant alleged that the Arkansas Department of Correction illegally changed his discharge date, holding that the circuit court correctly denied the petition and amended petition.After being sentenced in 2007, Defendant was paroled in 2015. Defendant was taken into custody a year later. In his petition and amended petition Defendant alleged that after revocation of his parole and his return to prison, he was informed that his discharge date had been illegally moved. The circuit court denied the petition for failure to state a claim for relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it denied Defendant's petitions for declaratory judgment and writ of mandamus. View "Andrews v. Payne" on Justia Law

The Supreme Court remanded this case to the circuit court, holding that remand was required to accurately settle the record, specifically concerning Defendant's exhibit 1, a conventionally-filed physical disk that was submitted as part of the record but contained no files.Defendant was convicted of first-degree murder and sentenced to life imprisonment with a fifteen-year enhancement for firearm use. At issue on appeal was whether the circuit court erred in denying Defendant's motion for a mistrial during the guilt phase of trial. The Supreme Court remanded the case, holding that remand was required to rectify gaps in the record. View "Petty v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's two petitions for declaratory judgment and writ of mandamus wherein Appellant asked the circuit court to declare that he was entitled to parole and to direct his release on parole from the Arkansas Division of Correction (ADC), holding that there was no error.Appellant filed petitions for declaratory judgment and writ of mandamus asserting that the ADC violated Ark. Code Ann. 16-93-615(h), which was codified as section 16-93-1302(f) at the time Appellant committed the crime of rape, by denying him parole. The circuit court dismissed the petition, concluding that the issues raised therein was been addressed and resolved in Carroll v. Hobbs, 442 S.W.3d 834 (Ark. 2014). The Supreme Court affirmed, holding that the circuit court did not clearly err or abuse its discretion by denying and dismissing Appellant's petitions for declaratory and mandamus relief. View "Carroll v. Payne" on Justia Law

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