Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed this appeal brought by Defendants Baptist Health Medical Center-Little Rock and Diamond Risk Insurance, LLC (collectively, Baptist) of the order of the circuit court denying Baptist's motion to dismiss Plaintiff's medical malpractice complaint, holding that the circuit court's order was not a final, appealable order.Plaintiff brought this complaint alleging that, for almost three months in 2021, he was a patient at Baptist fighting COVID-19 and was subjected to negligent care and treatment. Baptist filed a motion to dismiss, arguing that it was immune from suit pursuant to Executive Order 20-52, which established that healthcare providers were immune from liability while treating patients with COVID-19. The circuit court denied the motion to dismiss. The Supreme Court denied Defendants' subsequent appeal, holding this Court lacked jurisdiction because the immunity at issue was one of liability rather than immunity from suit. View "Baptist Health v. Sourinphoumy" on Justia Law

The Supreme Court affirmed in part and reversed and dismissed in part a sentencing order convicting Appellant of twenty-five counts of possessing or viewing matter depicting sexually explicit conduct involving a child and sentencing him to forty-two years' imprisonment, holding that certain counts are reversed and dismissed for a failure of proof that the images underlying those counts contained matter depicting or incorporating the image of a child as defined by Ark. Code Ann. 5-27-601(1).Pursuant to a search warrant, law enforcement officers searched Defendant's residence and seized several electronic devices. A forensic examination of the devices revealed images that were pornographic in nature involving children. Some were computer-generated imagery (CGI) and some were actual photographs. Among his allegations of error on appeal, Appellant argued that the individuals depicted in the CGI did not meet the legal definition of a "child." The Supreme Court agreed and reversed and dismissed counts 1, 15-16, and 23-30, holding that the State failed to present evidence on each of those counts that the underlying CGI images depicted or incorporated the images of a child, and therefore, the evidence was insufficient to sustain those convictions. View "Lewis v. State" on Justia Law

The Supreme Court dismissed this appeal brought by the State claiming an error in Defendant's criminal proceedings regarding a speedy-trial ruling, holding that the State's appeal was not authorized under Ark. R. App. P.-Crim. 3.Defendant was charged for driving while intoxicated. Defendant later filed a motion to dismiss the prosecution based on a speedy-trial violation. The trial court granted the motion, ruling that the charges be dismissed based on a speedy-trial violation. The State appealed, essentially challenging the circuit court's findings of fact regarding the speedy-trial calculation. The Supreme Court dismissed the appeal, holding that the appeal was not authorized under Rule 3 because it did not present an issue of interpretation of a criminal rule that would have widespread ramifications. View "State v. Pate" on Justia Law

The Supreme Court affirmed the order of the circuit court entering judgment upon a jury verdict finding Defendant guilty of rape and sentencing him to life in prison, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued, among other things, that the State intentionally circumvented his right to confront vital witnesses by improperly allowing into evidence a surreptitious recording made by Defendant's roommate and that the recording contained inadmissible hearsay. The Supreme Court affirmed, holding (1) there was sufficient evidence to support the rape conviction; and (2) the circuit court did not err in admitting the recording into evidence. View "Wallace v. State" on Justia Law

The Supreme Court vacated the order of the circuit court declaring Act 1002 of 2021 to be unconstitutional and permanently enjoining its enforcement, holding that the circuit court did not have subject matter jurisdiction to enter the order.The Act, codified at Ark. Code Ann. 20-7-144, prohibited state agencies, political subdivisions of the state, and local and state officials from mandating the use of face masks, face shields, or other face coverings. Two lawsuits were filed seeking to declare the Act unconstitutional and enjoin its enforcement. The circuit court consolidated the cases, enjoined enforcement of the Act, and preliminary declared the Act unconstitutional in violation of the separation of powers and equal protection clauses of the state Constitution. The Supreme Court vacated the order below, holding that the circuit court lacked jurisdiction to enter the final order because an interlocutory appeal was still pending. View "State v. McClane" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for writ of habeas corpus, holding that Petitioner's statutory and constitutional claims did not raise jurisdictional issues that entitled him to habeas relief.Petitioner was convicted of capital murder and first-degree battery and sentenced to a life sentence plus consecutive twenty-four sentences. The Supreme Court affirmed on direct appeal. Petitioner later brought this petition alleging that he was not named in the body of the criminal information and that he was not identified in the document, and therefore, the trial court lacked jurisdiction over him. The circuit court denied the habeas corpus petition. The Supreme Court affirmed, holding that the trial court had personal and subject-matter jurisdiction over Petitioner. View "Lee v. Payne" on Justia Law

The Supreme Court dismissed Appellant's appeal of the circuit court's order denying Appellant's motion for a new trial based on allegations of juror misconduct, holding that both Appellant's motion for new trial and notice of appeal were filed untimely.Appellant was convicted of first-degree murder and sentenced to life in prison. Appellant later filed a petition for writ of habeas corpus and motion for new trial, alleging juror misconduct. The trial court denied the petition and the motion. The Supreme Court dismissed Appellant's appeal of the denial of his motion for a new trial, holding that the circuit court lacked jurisdiction to hear the motion. View "Herron v. Ark. Dep't of Corrections" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of multiple counts of rape, second-degree sexual assault, sexual indecency with a child, engaging a child in sexually explicit conduct for use in visual or print medium and other offenses, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported Defendant's forty-one convictions; (2) Defendant's argument that the State improperly relied on a religious text to urge a conviction during closing argument was not preserved for appeal; and (3) Defendant's arguments regarding his sentence of life imprisonment plus 488 years were not preserved for appellate review. View "Break v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of Municipal Health Benefit Fund and dismissing this class action complaint challenging the Fund's decision to deny payment for portions of Plaintiff's daughter's medical bills based on its interpretation of the uniform, customary, and reasonable charges (UCR) exclusion in the Fund's policy booklet, holding that there was no error.Through his employment with a municipal police department, Plaintiff obtained health benefits coverage through the Fund. After Plaintiff's daughter was injured in a car accident the Fund denied payment for portions of her medical bills based on its interpretation of the UCR exclusion. Plaintiff then brought this class action against the Fund challenging the enforcement of the UCR term. The circuit court granted class certification and later granted summary judgment in favor of the Fund. The Supreme Court affirmed, holding that the circuit court did not err in granting summary judgment in favor of the Fund. View "Hendrix v. Municipal Health Benefit Fund" on Justia Law

The Supreme Court affirmed the order of the circuit court convicting Appellant of capital murder and sentencing him to life imprisonment, holding that not prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported Appellant's capital murder conviction; (2) the circuit court did not abuse its discretion in the guilt phase of trial by excluding the victim's emergency room medical records and a death certificate; and (3) Appellant's argument that the deputy chief medical examiner provided invalid forensic testimonial evidence and resulted in his conviction was not preserved for appeal. View "May v. State" on Justia Law