Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for postconviction relief filed pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not er in denying Appellant's petition to correct an illegal sentence.Appellant was found guilty of first-degree murder and committing a terroristic act and was sentenced to two life sentences. Appellant later filed his petition to correct an illegal sentence. The trial court denied the petition on the grounds that it was not timely filed and that the sentence imposed was valid. The Supreme Court affirmed, holding that Appellant was not entitled to relief. View "Starling v. State" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that none of the allegations raised by Appellant established that his sentence was facially illegal.Appellant entered a guilty plea to four counts of aggravated robbery and other offenses and was sentenced to an aggregate term of 420 months' imprisonment. Appellant later filed a pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1 and a pro se petition for reduction of sentence pursuant to Ark. Code Ann. 16-90-111. In his petition to correct an illegal sentence Appellant argued, inter alia, that his sentence was illegal because he was not eligible for a suspended sentence due to his status as a habitual offender. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief to correct an illegal sentence because his sentences were not illegal. View "Carter v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's petition for writ of habeas corpus, holding that Appellant's sentencing order was not facially invalid.In 1981, at the age of seventeen, Appellant was charged with two counts of capital murder. The circuit court sentenced Appellant to a term of life imprisonment. In 2020, Appellant filed a petition for a writ of habeas corpus asserting that he had been held unlawfully pursuant to Miller v. Alabama, 567 U.S. 460 (2010). The circuit court dismissed the petition. The Supreme Court affirmed, holding that Appellant's argument was barred by the issue-preclusion element of res judicata. View "Brown v. State" on Justia Law

The Supreme Court reversed the order of the circuit court affirming a decision of the Arkansas Department of Finance and Administration (DFA) concerning certain adjustments to Cenark Investment Group, LLC's taxable income and to its shareholders' accounts for tax years 2016-2018, holding that the circuit court misinterpreted Ark. Code Ann. 26-18-406.Specifically at issue was the circuit court's interpretation section 26-18-406, which provides that a lawsuit brought in circuit court to contest a DFA assessment "shall be tried de novo." On appeal, Cenark argued that the circuit court erred in affirming DFA's decision without holding a trial de novo pursuant to section 26-18-406. For the reasons set forth in A-1 Recovery Towing and Recovery, Inc. v. Walther, 2023 Ark.___ (CV-22-281), also decided today, the Supreme Court reversed and remanded this case for further proceedings. View "Cenark Investment Group, LLC v. Walther" on Justia Law

The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus filed pursuant to Ark. Code 16-112-101 to -123, holding that Appellant was not entitled to relief on his claims of error.Appellant, who was eighteen years old when he committed murder, pleaded guilty to capital murder and was sentenced to life parole. Four decades later, Appellant filed his pro se petition for writ of habeas corpus, seeking an expansion of the holding in Miller v. Alabama, 567 U.S. 460 (2012), to individuals between the ages of eighteen to twenty-one. The circuit court dismissed the petition. The Supreme Court affirmed, holding that the circuit court did not err in dismissing the petition without holding a hearing. View "Gibbs v. Payne" on Justia Law

The Supreme Court reversed the order of the circuit court affirming the decision of the Arkansas Department of Finance and Administration (DFA) concerning its adjustments made to A-1 Recovery Towing & Recovery, Inc.'s taxable income and to its shareholders' accounts for tax years 2013-2017, holding that the circuit court failed to follow Ark. Code Ann. 26-18-406 when it affirmed DFA's decision sua sponte.Section 26-18-406 provides that a suit in circuit court to contest a DFA assessment "shall be tried de novo." On appeal, A-1 argued that the circuit court erroneously sua sponte entered its order affirming the DFA's decision because the order deprived A-1 of its right to a trial de novo under section 26-18-406. The Supreme Court agreed and reversed, holding that the circuit court deprived A-1 of its opportunity to meet proof with proof prior to affirming DFA's decision sua sponte. View "A-1 Recovery Towing & Recovery, Inc." on Justia Law

The Supreme Court rescinded an earlier decision to answer a certified question of law certified by the United States District Court for the Eastern District of Arkansas, holding that certification was improvidently granted.Plaintiff filed suit in the district court seeking to recover corrective fees it incurred in the underlying case. The district court concluded that Plaintiff could not establish proximate cause under Arkansas law and denied the motion. The United States Court of Appeals for the Eighth Circuit reversed and remanded the case for further proceedings. On remand, the district court certified a question of law regarding proximate cause in a legal malpractice action and corrective fees. The Supreme Court accepted the question of law. The Court then exercised its discretion to rescind its decision to answer the questioned question because the Eighth Circuit had already addressed the issue involved in the certified question presented to the Supreme Court. View "Gerber Products Co. v. Mitchell, Williams, Selig, Gates & Woodyard, PLLC" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order dismissing Appellant's appeal from the district court absent a conviction as required by Ark. R. Crim. P. 36(a), holding that the district court illegally imposed court costs and probation in violation of Appellant's state and federal constitutional due process rights and his federal and state constitutional right to a trial.Appellant pled guilty to carrying a weapon in a publicly owned building. The district court ordered Appellant to pay court costs of $140 and told Appellant if there were no further charges within thirty days the charge would be dismissed. The court dismissed the case at the end of thirty days for lack of jurisdiction on the grounds that there was no underlying conviction. The Supreme Court reversed in part, holding that the court had jurisdiction to hear Appellant's challenge to the legality of his de facto sentence, and Appellant should have been heard on the merits. View "Gillette v. City of Fort Smith" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's complaint for declaratory judgment and injunctive relief and petition for writ of mandamus seeking to direct Appellees to allow Appellant to carry a firearm inside the district court, holding that there was no error.Appellant, an attorney, filed a complaint for declaratory judgment and injunctive relief seeking a declaration that Act 1087 of 2017, codified at Ark. Code Ann. 5-73-122(b), authorizes attorneys as "officers of the court" to carry a firearm in any of the state's courts or courthouses and a declaration that Appellees' conduct in refusing to allow Appellant to enter the Pulaski County District Courthouse with a firearm violated Arkansas law. Appellant further sought mandamus relief asking that the court direct Defendants to permit attorneys in court with a firearm. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err in denying Appellant's mandamus petition. View "Corbitt v. Pulaski County Jail" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment, granted appellate counsel's motion to withdraw as counsel, and remanded the case for a correction of a clerical error in the sentencing, holding that no reversible error occurred in the proceedings below.After his conviction, Defendant filed a timely appeal, and his attorney filed a no-merit brief. The Supreme Court declined to grant relief, holding (1) the circuit court did not err in denying Defendant's motion for a directed verdict and his renewed motion for directed; (2) the circuit court did not abuse its discretion in sustaining the State's hearsay objection to certain testimony; and (3) while an error in the sentencing order was not grounds for reversal, remand was required for correction. View "Humphry v. State" on Justia Law