Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court dismissed the order of the circuit court denying Appellant's motion for new trial based on allegations of juror misconduct, holding that the motion was clearly untimely, and therefore, the circuit court did not have authority to act on Appellant's motion when it entered orders in this action.In 2004, Appellant was convicted of first-degree murder and sentenced to life imprisonment. In 2018, Appellant filed a petition for writ of habeas corpus and motion for new trial alleging juror misconduct. The trial judge dismissed the habeas petition without prejudice and denied the motion for new trial. The Supreme Court dismissed the appeal, holding that Appellant's motion for new trial was untimely, and the circuit court lacked jurisdiction to consider the motion. View "Herron v. Ark. Department of Corrections" on Justia Law

The Supreme Court affirmed the decision of the Arkansas Client Security Fund Committee denying Appellant's application for the reimbursement of client funds, holding that the Committee properly denied Appellant's application for relief because his application was untimely.Appellant, who was incarcerated for second-degree sexual assault, filed an application for relief with the Fund seeking $2500 in reimbursement from his former attorney Thomas Wilson. The Committee denied the application pursuant to Rule 4(B) of the Rule of the Client Security Fund Committee. The Supreme Court affirmed, holding that Appellant's application was not filed within the three-year time frame set forth in Rule 4(B). View "Curran v. Ark. Client Security Fund" on Justia Law

The Supreme Court reversed the order of the circuit court disqualifying Risie Howard as the attorney representing the estate of Mrs. George Howard in a case arising from Mrs. Howard's medical treatment, holding that the circuit court's ruling represented a manifest abuse of discretion.On appeal, Howard argued that the circuit court erroneously interpreted Rule 3.7 of the Arkansas Rules of Professional Conduct and misapplied the test promulgated in Weigel v. Farmers Insurance Co., 158 S.W.3d 147 (Ark. 2004), in granting Defendants' motion to disqualify her. The Supreme Court reversed, holding that the circuit court did not faithfully apply Rule 3.7 and the precedent established by Weigel and its progeny in disqualifying Howard. View "Howard v. Baptist Health" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying relief in this Administrative Procedure Act (APA) appeal of the Colonel William J. Bryant's denial of Appellant's application to obtain a license for his private security and investigations company, holding that there was no error.Col. Bryant, in his capacity as director of the Arkansas State Police, entered an administrative order finding that Appellant was ineligible to receive a license due to his prior convictions. Appellant filed a petition for judicial review. After a remand, the circuit court denied the petition finding that there was substantial evidence to support the agency's decision. The Supreme Court affirmed, holding (1) Appellant cited no authority for the proposition that it was reversible error for the circuit court to decide an APA appeal on a different ground than that found by the administrative agency; and (2) the director did not err in determining that Ark. Code Ann. 17-40-306 controlled over Ark. Code Ann. 17-1-103. View "Hackie v. Bryant" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court awarding $18,160,000 in attorneys' fees to Appellees, holding that the circuit court erred in its award of attorneys' fees and costs but did not err in denying Appellees' motion for contempt.On appeal, certain appellants argued that the circuit court erred in its application of the factors set forth in Chrisco v. Sun Industries, 800 S.W.2d 717 (Ark. 1990) and that they should not have to pay attorneys' fees. Other appellants argued that sovereign immunity barred the fee award. Appellees cross-appealed, arguing that the circuit court erred in denying their motion for contempt. The Supreme Court held (1) in the absence of express statutory authority, the circuit court abused its discretion in awarding a flat fifteen percent attorneys' fee award of $18.16 million in attorneys' fees and costs; and (2) the circuit court properly denied Appellees' contempt motion. View "Gibson v. Buonauito" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting Petitioner's motion for judgment on the pleadings, entering judgment in Petitioner's favor for the relief requested in his petition, and denying the Director of the Division of Correction's motion for summary judgment, holding that the circuit court erred.Petitioner pleaded guilty to first-degree murder and aggravated assault. After the General Assembly passed the Fair Sentencing of Minors Act (FSMA), which contained parole-eligibility provisions that applied retroactively to Petitioner, Petitioner filed a petition for declaratory judgment, injunctive relief, and mandamus relief seeking to resolve any uncertainty regarding the FSMA as applied to him. The circuit court granted Petitioner's motion for judgment on the pleadings and denied the Board's motion for summary judgment, finding that Ark. Code Ann. 16-93-621(a)(2)(A) applied retroactively to Petitioner's sentences. The Supreme Court reversed, holding that the circuit court erred in its interpretation of section 16-93-621(a) and by finding that Petitioner was parole eligible after serving twenty-five years' imprisonment. View "Arkansas Parole Bd. v. Johnson" on Justia Law

The Supreme Court granted the petition brought by the Arkansas Judicial Discipline and Disability Commission claiming that Judge Carroll violated several rules of the Arkansas Code of Judicial Conduct, including breaching his duty to the public and undermining the fair and impartial administration of justice, holding that disciplinary action was required.In its petition, the Commission agreed to recommend a suspension without pay for ninety days, with thirty days held in abeyance for one year, and certain remedial measures for Judge Carroll's improprieties. The Supreme Court granted the Commission's expedited petition and modified the recommendation sanction by suspending Judge Carroll without pay for eighteen months, with six of those months held in abeyance. The Court further ordered Judge Carroll to perform an assessment and complete a plan with the Judges and Lawyers Assistance Program, holding that, given the seriousness of the conduct at issue, the length of the recommended suspension was insufficient. View "Ark. Judicial Discipline & Disability Comm'n v. Carroll" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's multiple claims of ineffective assistance of counsel, holding that the circuit court did not err on Appellant's seven separate claims of ineffective assistance of counsel.Appellant was convicted of second-degree murder and sentenced to life in prison. Appellant later filed a petition under Ark. R. Crim. P. 37 arguing that the circuit court erred on seven distinct allegations of ineffective assistance of counsel. The Supreme Court affirmed, holding that none of Appellant's arguments on appeal had merit and that the circuit court did not err in denying postconviction relief. View "Gentry v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court convicting Defendant of two counts of rape, sexual assault in the second degree, and sexually grooming a child, holding that remand was required for entry of a corrected sentencing order in which Defendant was not assessed a cybercrime fee.Specifically, the Supreme Court held (1) the evidence was sufficient to support Defendant's convictions for rape and sexually grooming a child; (2) the circuit court did not err in denying Defendant's motion to introduce certain evidence under the rape-shield statute, Ark. Code Ann. 16-42-101; and (3) the circuit court erred by assessing a $150 cybercrime fee because the State failed to meet the requirements of Ark. Code Ann. 5-4-706(b). View "Hartley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of capital murder, abuse of a corpse, and theft of property, holding that Defendant was not entitled to reversal of his convictions based on his allegations of error.On appeal, Defendant argued, among other things, that the district court erred when it denied his directed verdict motion on the charges. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case excluded every reasonable hypothesis other than Defendant's guilt; (2) the circuit court did not err in denying Defendant's motion to suppress; and (3) the circuit court did not abuse its discretion by admitting into evidence autopsy photos. View "Cone v. State" on Justia Law