Justia Arkansas Supreme Court Opinion Summaries

An emergency-room physician and his girlfriend were driving on a highway when the girlfriend died under suspicious circumstances. The physician was the only person present with her at the time. He called 911 and told responders that she was having a seizure. Passersby and responders noted that the physician acted erratically and did not attempt to help. Medical personnel observed significant injuries to the girlfriend’s neck, and an autopsy concluded that she died from strangulation, though the defense’s expert disputed the cause. Text messages presented at trial revealed prior threats from the physician toward the girlfriend.The case was tried in the Chicot County Circuit Court before a jury, which heard conflicting testimony from expert witnesses about the cause of death. The defense argued that the cause was undetermined and that death could have resulted from medical intervention or natural causes. The State’s expert concluded the death was a homicide by strangulation. The jury found the physician guilty of second-degree murder and he was sentenced to thirty years’ imprisonment and fined. After trial, the defense moved for a new trial, alleging juror misconduct based on an affidavit from a juror. The trial court held a hearing, heard testimony from the relevant jurors, and denied the motion for a new trial, finding no credible evidence of misconduct.The Supreme Court of Arkansas reviewed the appeal and held that there was substantial evidence to support the conviction for second-degree murder, that the circuit court did not abuse its discretion in instructing the jury on second-degree murder as a lesser-included offense, and that there was no reversible error in denying the motion for a new trial based on alleged juror misconduct. The Supreme Court of Arkansas affirmed the conviction and vacated the Court of Appeals' opinion. View "TAIT v. STATE OF ARKANSAS" on Justia Law

The case concerns a man convicted of first-degree murder and a firearm enhancement following the fatal shooting of his business partner outside her home. The two had operated a food-truck business together, and on the day in question, the defendant was seen at the victim’s home with her truck. Several eyewitnesses, including members of the victim’s family and neighbors, testified about the events surrounding the shooting, identifying the defendant as present at the scene and as the person leaving in the victim’s truck after the shooting. After the crime, the defendant abandoned his business and job and evaded police for months, fleeing from law enforcement in both Texas and West Virginia before being apprehended. The Pulaski County Circuit Court, Seventh Division, presided over the defendant’s postconviction petition, which was filed under Arkansas Rule of Criminal Procedure 37.1. The defendant, initially pro se and later represented by counsel, alleged ineffective assistance of trial counsel on five grounds. At a hearing, the court considered evidence and testimony, including from trial counsel and an investigator. The court found that the defendant failed to show trial counsel’s performance was deficient under the standard established by Strickland v. Washington, and that no prejudice resulted from the alleged deficiencies. The court denied the petition. The Supreme Court of Arkansas reviewed the case. Applying the “clearly erroneous” standard, the court examined the trial court’s findings and the three ineffective-assistance claims raised on appeal: insufficient cross-examination of witnesses, failure to investigate the crime scene, and failure to obtain dashcam footage of the police chase. The Supreme Court concluded that the record showed effective cross-examination, that information about the scene was provided to the jury, and that counsel’s actions regarding the dashcam did not constitute ineffectiveness. The Supreme Court affirmed the lower court’s denial of postconviction relief. View "DORSEY v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury in Johnson County, Arkansas, of capital murder, aggravated robbery, and theft of property. The evidence at trial included admissions by the appellant that he intended to rob the victim, that he stabbed her in the throat (which was the fatal wound), and that he stole her car and used her credit cards after her death. DNA evidence connected the appellant to the victim, and multiple witnesses, including the appellant’s sister and a friend, testified to his admissions and actions following the crime. After his conviction was affirmed on direct appeal by the Supreme Court of Arkansas, the appellant filed a petition for postconviction relief under Arkansas Rule of Criminal Procedure 37.1 in the Johnson County Circuit Court. He claimed ineffective assistance of counsel for failure to investigate a laptop allegedly containing exculpatory evidence and unidentified DNA found on a knife, asserted a violation under Brady v. Maryland for alleged suppression of the laptop, and argued that the prosecutor knowingly presented false testimony. The circuit court denied and dismissed the petition, finding that the claims were not supported by the record or were not cognizable in a Rule 37.1 proceeding. The Supreme Court of Arkansas reviewed the case and affirmed the circuit court’s denial and dismissal of the appellant’s petition. The court held that the appellant failed to present evidence supporting his claims, and his ineffective assistance of counsel argument lacked factual substantiation. The court also found the Brady claim and the argument regarding false testimony were either unsupported by evidence or not appropriate for postconviction relief under Rule 37.1. The Supreme Court of Arkansas concluded that the circuit court did not clearly err and affirmed its decision. View "OLIGER v. STATE OF ARKANSAS" on Justia Law

A candidate for the Arkansas House of Representatives was challenged by his opponent, who argued that she was ineligible to run for office due to a prior disposition in a 2018 hot-check case. The challenger claimed that the opponent had been found guilty of violating the Arkansas Hot Check Law, which, under state constitutional and statutory provisions, would render her ineligible for election. The evidence included a district court docket showing a disposition labeled “GUILTY – BOND FORFEITURE,” as well as payment of fines, fees, and restitution related to the charge. The opponent did not contest the existence of the underlying case but denied that she had been convicted or found guilty.The case was first heard in the Pulaski County Circuit Court. After a hearing that included testimony from court and law enforcement personnel about the court’s procedures, and review of the district court records, the circuit court concluded that the bond forfeiture was not an admission of guilt. The court found that the opponent had neither entered a plea nor been found guilty by the court. The circuit court therefore held that she had not been convicted of an infamous crime or a public trust crime under Arkansas law, and denied the challenger’s petition for declaratory judgment and mandamus.On appeal, the Supreme Court of Arkansas reviewed the record and the circuit court’s findings under a clearly erroneous standard. The Supreme Court affirmed the lower court’s decision, holding that a bond forfeiture, without a plea or factual finding of guilt, does not constitute a conviction or render a candidate ineligible under Article 5, Section 9 of the Arkansas Constitution or the relevant statutes. The Supreme Court rejected the challenger’s remaining arguments and affirmed the circuit court’s judgment. View "DAY V. WARDLAW" on Justia Law

A juvenile was arrested at age twelve for the murder and aggravated robbery of a convenience store clerk. Surveillance video showed the juvenile entering the store multiple times, stealing items, and ultimately shooting the victim eight times. After the murder, he calmly stole additional items and discarded evidence. The juvenile confessed to the crimes and exhibited a history of violent and antisocial behavior, documented by family members, school officials, therapists, and juvenile detention staff. Multiple psychological evaluations were conducted, yielding conflicting diagnoses of autism, conduct disorder, and schizophrenia, but all agreed he knew right from wrong.The juvenile division of the Miller County Circuit Court designated him as an extended juvenile jurisdiction (EJJ) offender. He was adjudicated delinquent by a jury, committed to the Arkansas Division of Youth Services (DYS), and the imposition of an adult sentence was suspended pending further review. The Arkansas Court of Appeals affirmed these rulings. Over several years, DYS provided rehabilitative services. After several petitions concerning release and adult sentencing, the State filed a petition to impose an adult sentence as the juvenile approached age twenty, citing ongoing concerns about rehabilitation and public safety. At the subsequent hearing, DYS staff testified that the juvenile had made progress and completed treatment goals, but the State introduced evidence of recent violent incidents and inconsistencies in staff testimony.The Supreme Court of Arkansas reviewed the circuit court’s order imposing an adult sentence, applying a clearly erroneous standard. The court affirmed the circuit court’s findings that the juvenile was not amenable to treatment and that public safety required the imposition of an adult sentence. The court held that the circuit court’s assessment of the statutory factors and credibility determinations were not clearly erroneous, and affirmed the life sentence with the possibility of parole after thirty years. View "MERRELL v. STATE OF ARKANSAS" on Justia Law

Kent Parris was apprehended after selling fentanyl, methamphetamine, and drug paraphernalia to a confidential informant during a law enforcement sting operation near a church. Following the transaction, Parris fled in his vehicle but was eventually stopped by officers, who found marked bills and various drugs on his person and in his car. During a search along the route of the brief vehicle chase, police recovered a bag containing methamphetamine and a backpack with a loaded handgun and additional pills. At trial, evidence included audio recordings, body camera footage, physical drug evidence, and the items seized from Parris and the scene.The Arkansas County Circuit Court jury convicted Parris on multiple counts: possession of fentanyl and cocaine with intent to deliver, possession of drug paraphernalia to manufacture, delivery of methamphetamine and fentanyl, simultaneous possession of drugs and firearms, and theft by receiving a firearm. The jury imposed consecutive sentences totaling life plus 185 years, with an additional concurrent ten-year enhancement for committing drug crimes within one thousand feet of a church. Parris challenged the sufficiency of the evidence for several convictions and contested the enhancement.The Supreme Court of Arkansas reviewed the case and affirmed all convictions and the sentence enhancement except for the theft-by-receiving conviction. The court held that substantial evidence supported the drug-related convictions and the simultaneous possession charge, relying on both direct and circumstantial evidence. However, regarding theft by receiving, the court found that the only evidence the firearm was stolen was inadmissible hearsay from a police officer referencing a report. Concluding there was insufficient evidence that the firearm was stolen property, the court reversed the theft-by-receiving conviction and remanded the case to the circuit court for a new sentencing order. The remaining convictions and enhancements were affirmed. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

A man was convicted by a jury of raping his then-girlfriend’s 14-year-old daughter, following evidence that included sexually explicit electronic messages he sent to the minor, testimony from the victim about the assault, and testimony from another of his daughters describing similar sexual abuse. The victim disclosed the assault to her mother immediately after it occurred, but her mother did not initially believe her or contact authorities. Several years later, the mother received messages from the defendant describing further sexual abuse of his other children; these messages ultimately led to the involvement of law enforcement and the defendant’s arrest and prosecution.The Garland County Circuit Court admitted the contested electronic messages into evidence, finding sufficient authentication through the testimony of the recipients. The court also allowed the defendant’s other daughter to testify to similar abuse under the “pedophile exception” to Arkansas Rule of Evidence 404(b), determining the testimony was more probative than prejudicial. The defendant moved for a continuance after being charged with additional sexual offenses days before trial, but the circuit court denied the motion, finding he was able to assist his counsel. After conviction, the court sentenced him to life in prison.On appeal to the Supreme Court of Arkansas, the defendant challenged the sufficiency of the evidence, the admission of the electronic messages and other-acts testimony, the denial of the continuance, and the constitutionality of his life sentence. The Supreme Court of Arkansas affirmed the conviction and sentence. It held that substantial evidence supported the jury’s finding that the defendant was in a position of authority over the victim as required by statute; the circuit court did not abuse its discretion in its evidentiary rulings or in denying the continuance; and the life sentence for child rape was not unconstitutional under either the Eighth Amendment or the Arkansas Constitution. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

During a law enforcement sting operation, the defendant sold fentanyl, methamphetamine, and drug paraphernalia near a church to a confidential informant. After the transaction, officers attempted to stop him, leading to a brief chase. The defendant was apprehended, and police recovered marked bills, various drugs, digital scales, and, along the route of the chase, a clear bag containing methamphetamine and a black bag containing a handgun and pills. Physical evidence and video footage of the transaction were introduced at trial. The pills were confirmed to contain fentanyl, and the cocaine found was packaged in a manner consistent with distribution.The Arkansas County Circuit Court jury convicted the defendant of multiple drug offenses, simultaneous possession of drugs and a firearm, and theft by receiving a firearm. He was sentenced to life plus an additional 185 years, with sentences to run consecutively, and a ten-year enhancement for drug crimes near a church. The defendant appealed, challenging the sufficiency of the evidence on all convictions and the sentence enhancement.The Supreme Court of Arkansas reviewed the evidence in the light most favorable to the verdict and found substantial evidence supporting all the drug-related convictions and the enhancement. The court held that circumstantial evidence sufficiently linked the defendant to the drugs and firearm found during the chase, allowing for the simultaneous possession conviction. However, the court determined there was not substantial evidence to support the theft-by-receiving conviction because the only proof the firearm was stolen was inadmissible hearsay testimony from an officer regarding a database entry. The Supreme Court of Arkansas affirmed all convictions except the theft-by-receiving conviction, which it reversed and remanded for entry of a new sentencing order. View "PARRIS v. STATE OF ARKANSAS" on Justia Law

The appellant was convicted by a jury of raping the 14-year-old daughter of his then-live-in girlfriend. The evidence included testimony that he sent the victim sexually explicit messages, gave her alcohol, and raped her while she was intoxicated. Several years later, after the appellant described to the victim’s mother in a series of electronic messages how he had raped his own daughters, the mother reported the abuse. Further testimony was provided by one of the appellant’s daughters, who described a longstanding pattern of sexual abuse and grooming by the appellant. The appellant was sentenced to life in prison.Prior to this appeal, the Garland County Circuit Court presided over the trial. The appellant moved for a continuance after being charged in a separate case with raping another of his daughters, arguing that the new charges impaired his ability to participate in his defense. The circuit court denied the motion, finding the appellant was able to assist his counsel. The court also overruled the appellant’s objections to the admission of explicit electronic messages and testimony from his daughter describing other uncharged sexual offenses, concluding that authentication and evidentiary standards were met. The jury convicted the appellant and imposed a life sentence.On review, the Supreme Court of Arkansas addressed the appellant’s challenges to both his conviction and sentence. The court held that substantial evidence supported the jury’s finding that the appellant was in a position of authority over the victim as required by Arkansas law. The court found no abuse of discretion in the denial of the continuance or in the admission of the challenged evidence, holding that the evidence was properly authenticated and the testimony of the appellant’s daughter was admissible under the “pedophile exception” to Arkansas Rule of Evidence 404(b). The court further held that the life sentence did not violate the Eighth Amendment or the Arkansas Constitution. The judgment was affirmed. View "FAULKNER V. STATE OF ARKANSAS" on Justia Law

A seventeen-year-old was charged in the St. Francis County Circuit Court with three counts of capital murder and one count of felony theft after his mother, her boyfriend, and his twelve-year-old sister were found shot to death in their home. The evidence included the recovery of the victims’ vehicle, a firearm, gunshot residue on the accused’s clothing, and DNA evidence. The accused denied involvement but was contradicted by testimony from his four-year-old sister and other evidence. The defense presented testimony about his background, mental health, and the potential for rehabilitation.After the accused moved to transfer the case to the juvenile division, the St. Francis County Circuit Court held a hearing and denied the motion. On interlocutory appeal, the Arkansas Court of Appeals found that the circuit court had failed to address a required statutory factor and remanded for additional findings. The circuit court entered an amended order again denying transfer. The accused then appealed to the Arkansas Supreme Court.The Arkansas Supreme Court first ruled that the accused's constitutional challenge to Arkansas Code Annotated section 9-27-318 was not preserved for appellate review because it was not raised in the circuit court. The court also held that the circuit court properly exercised subject-matter jurisdiction. Reviewing the denial of transfer for clear error, the Arkansas Supreme Court concluded that the amended order adequately addressed all statutorily required factors, gave appropriate weight to the seriousness and violent nature of the offenses, and was not clearly erroneous. The Supreme Court affirmed the circuit court’s denial of the motion to transfer the case to the juvenile division. View "ROLFE v. STATE OF ARKANSAS" on Justia Law