Justia Arkansas Supreme Court Opinion Summaries

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

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