Justia Arkansas Supreme Court Opinion Summaries

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

Keeling Grubb, acting as president and CEO of Eureka Gun and Pawn, LLC, sought a conditional-use permit (CUP) from the City of Eureka Springs to operate the business as a gun and pawn shop. Grubb submitted the application in May 2023, but the City’s Planning Commission denied it at a special meeting, and the denial was subsequently upheld by the Eureka Springs City Council. After these denials, Grubb and Eureka Gun filed a complaint in Carroll County Circuit Court, challenging the City’s actions and advancing multiple constitutional and statutory claims related to due process, equal protection, property rights, freedom of association and speech, as well as the right to bear arms.In Carroll County Circuit Court, the bench trial was expressly limited to count one of the complaint: an appeal of the City Council’s administrative decision denying the CUP. The remaining claims were reserved for future resolution. During trial, evidence was presented on the nature of the business and community views, but the primary issue was whether Eureka Gun was entitled to a CUP under the City's ordinance. The circuit court denied the appellants’ motion for partial summary judgment and granted the City’s motion for directed verdict, finding that Eureka Gun was not entitled to the permit. Additionally, the court ruled that Arkansas Code Annotated § 14-16-504(b)(1)(A) did not apply to the commercial sale of firearms.The Supreme Court of Arkansas reviewed the appeal. It held that the orders appealed from were not final because the circuit court had only adjudicated one of multiple claims, leaving the others pending, and no Rule 54(b) certificate was issued to permit an immediate appeal. Consequently, the Supreme Court dismissed the appeal without prejudice for lack of a final order and declined to address the merits. View "EUREKA GUN AND PAWN, LLC V. THE CITY OF EUREKA SPRINGS" on Justia Law

In this case, two licensed medical marijuana businesses in Arkansas challenged the validity of twenty-eight legislative amendments made by the Arkansas General Assembly to Amendment 98 of the Arkansas Constitution, which established a framework for medical marijuana use in the state. The businesses argued that these amendments were unconstitutional because they had not been submitted for voter approval, as they claimed was required, and that the amendments were not germane to the pertinent section as required by the constitutional language.The Pulaski County Circuit Court agreed with the plaintiffs, relying on the precedent set by Arkansas Game & Fish Commission v. Edgmon, and ruled that the General Assembly lacked authority to amend a voter-initiated constitutional amendment without submitting those amendments to a public vote. The court also found that the legislative amendments were not germane to section 23 of Amendment 98 and were therefore unconstitutional and void. The State of Arkansas appealed this ruling.The Supreme Court of Arkansas reviewed the case and reversed the circuit court’s decision. The court held that Article 5, section 1 of the Arkansas Constitution does grant the General Assembly authority to amend voter-initiated laws, including initiated constitutional amendments, by a two-thirds vote of both legislative chambers. The court explicitly overruled Arkansas Game & Fish Commission v. Edgmon, finding its reasoning inconsistent with the plain constitutional text. Additionally, the court determined that the word “section” in section 23(a) of Amendment 98 should be interpreted as “amendment,” so the germaneness requirement applies to the amendment as a whole. Consequently, the Supreme Court of Arkansas reversed and dismissed the lower court’s ruling. View "STATE OF ARKANSAS v. GOOD DAY FARM ARKANSAS, LLC" on Justia Law

Reggie Matthews was convicted of capital murder for killing Tiana Robinson, with whom he had a tumultuous and abusive relationship. In the year leading up to Robinson’s death, Matthews demonstrated escalating threats, including refusing to leave Robinson’s home, making armed threats, and being reported for prowling near her residence shortly before the murder. On September 6, 2023, at a barbecue in Osceola, Arkansas, Matthews arrived, pursued Robinson as she attempted to flee, and shot her multiple times in the back. Multiple eyewitnesses identified Matthews as the shooter. After the crime, Matthews was arrested and made statements to police following a brief invocation of his right to counsel.In the Mississippi County Circuit Court, Matthews challenged his conviction on several grounds. He argued that the evidence was insufficient to support the verdict, that his statements to police should have been suppressed after he invoked his right to counsel, that a police officer’s unsolicited reference to a bystander’s identification violated a pretrial order and required a mistrial, and that allowing an officer to testify about Matthews’s interrogation violated the best-evidence rule. The circuit court denied his motions for a directed verdict, suppression, and a mistrial, and allowed the officer’s testimony. Matthews was found guilty and sentenced to life without parole.On appeal, the Supreme Court of Arkansas reviewed each of Matthews’s claims. The court held that substantial evidence supported the jury’s verdict, as multiple eyewitnesses identified Matthews as the shooter and his actions demonstrated premeditation and deliberation. The court determined that Matthews’s post-arrest statements were admissible because he reinitiated communication with police after requesting counsel. The court also found no abuse of discretion in denying a mistrial and held that the best-evidence rule was not violated since the recording was admitted. The Supreme Court of Arkansas affirmed Matthews’s conviction and sentence. View "MATTHEWS V. STATE OF ARKANSAS" on Justia Law

A teenage boy was found delinquent for committing second-degree sexual assault against his five-year-old half-niece. On Thanksgiving Day 2022, while staying at the victim’s home, the boy digitally penetrated the child’s rectum on a living room couch. The incident ended when the victim’s mother entered the room. Later that day, the child disclosed the assault to her parents, who contacted police and took her to the hospital. A sexual-assault nurse found no observable injury but collected rectal swabs and underwear, both of which tested positive for male DNA, though not in sufficient quantity to identify a specific individual. About a week later, the victim gave a recorded forensic interview detailing the assault.The State of Arkansas filed a delinquency petition in the Saline County Circuit Court, Juvenile Division. At the bench trial, the victim testified about the assault. The defense sought to impeach her credibility by playing selected segments of her prior forensic interview, suggesting inconsistencies. The State moved to admit the full recording under Arkansas Rule of Evidence 803(25), arguing it was necessary for context. The circuit court admitted the entire recording after in camera review, found the victim credible, and adjudicated the boy delinquent for second-degree sexual assault.On appeal, the Supreme Court of Arkansas reviewed the sufficiency of the evidence and the admission of the entire recorded interview. The court held that substantial evidence, including the victim’s testimony, corroboration by her parents, and the DNA evidence, supported the delinquency adjudication. The court further held that, although Rule 803(25) did not authorize admitting the full recording, it was admissible for rehabilitation and context in light of the defense’s impeachment attempt. The Supreme Court of Arkansas affirmed the adjudication. View "MINOR CHILD v. STATE OF ARKANSAS" on Justia Law

The case concerns the December 26, 2020, shooting death of Shaletian Larry. The defendant, Lazarus Reaves, and Larry were in a relationship marked by repeated abuse, as shown by text messages, witness testimony, and prior police involvement. On the day of the incident, after an argument and an altercation in the car, several witnesses observed Larry attempting to escape from her moving vehicle before Reaves shot her in the back and left her on the roadside. Physical evidence, including blood in the car and a firearm linked to Reaves and Larry, supported the prosecution’s case.The Washington County Circuit Court convened a jury trial. The State presented its evidence, after which Reaves moved for a directed verdict on the capital murder and tampering charges, arguing insufficient proof of premeditation. The motion was denied by the circuit court judge. Reaves did not present any evidence in his defense. The jury found him guilty of both charges, and he was sentenced to life imprisonment without parole for capital murder and a concurrent six-year term for tampering with evidence.On appeal, the Supreme Court of Arkansas reviewed whether the evidence was sufficient to support the conviction for capital murder, specifically the element of premeditation and deliberation. The court held that, even with only a single gunshot wound, substantial evidence existed to support the jury’s finding of premeditated and deliberated intent to kill, based on the circumstances of the crime and Reaves’s prior conduct and threats. The court affirmed the conviction and the judgment of the Washington County Circuit Court. View "LAZARUS REAVES V. STATE OF ARKANSAS" on Justia Law

A fatal motor-vehicle collision occurred on September 23, 2021, when Cody Conboy, an employee of Comfort Systems USA (Arkansas), Inc., crossed the center line while driving from his home to a remote jobsite. The accident resulted in the deaths of Tammy Gardner and five-year-old Christopher Skala, and injuries to three-year-old Xavior Skala. Conboy regularly traveled to various worksites as part of his employment, and his employer provided compensation for travel or per diem. The estates of the decedents and the guardian for the injured child initiated legal action against Comfort Systems and Conboy, alleging both direct and vicarious liability under the doctrine of respondeat superior.The Independence County Circuit Court consolidated the related cases and ultimately granted summary judgment in favor of Comfort Systems. The circuit court concluded that the “going-and-coming” rule, which bars liability for accidents occurring during an employee’s commute, should apply not only in workers’ compensation cases but also in tort cases involving employer liability. The circuit court found that Conboy was not acting within the scope of his employment at the time of the accident, and that Comfort Systems had no control over his travel. Consequently, all claims against Comfort Systems were dismissed with prejudice, while claims against Conboy remained pending.The Arkansas Court of Appeals reversed and remanded, and after further appellate proceedings, the Supreme Court of Arkansas reviewed the case. The Supreme Court held that the going-and-coming rule from workers’ compensation law does not govern tort cases involving respondeat superior liability. Instead, Arkansas courts must apply traditional respondeat superior analysis to determine if an employee was acting within the scope of employment. The Supreme Court further found that summary judgment was improper because reasonable minds could differ as to whether Conboy was acting within the scope of his employment. The court also held it was error to grant summary judgment on direct-liability claims where no such relief was requested. The case was reversed and remanded, and the court of appeals’ opinion vacated. View "SKALA v. COMFORT SYSTEMS USA, INC." on Justia Law

On February 26, 2022, the appellant and another individual arrived at a Conway, Arkansas house where several people had gathered. After an argument broke out between the appellant and a partygoer, the appellant made threats and left. He later returned with his accomplice, both armed, and a gunfight ensued outside the house. One person was fatally wounded after being shot multiple times. During the incident, a third party arrived with his child, and their vehicle was struck by gunfire, with evidence suggesting the child was endangered. Police recovered numerous shell casings at the scene matching the weapons used by both the appellant and his accomplice. The appellant was charged with capital murder, two counts of aggravated assault, and a firearm enhancement.The case was tried before the Faulkner County Circuit Court. A jury convicted the appellant on all counts, and the court imposed a life sentence without parole for capital murder, concurrent five-year sentences for aggravated assault, and a consecutive ten-year sentence for the firearm enhancement. The enhancement for committing the crimes in the presence of a child was dropped by the State. The appellant timely filed a notice of appeal, challenging six evidentiary rulings made during the trial.The Supreme Court of Arkansas reviewed the case. Applying an abuse-of-discretion standard, the court addressed each evidentiary challenge, including hearsay objections, expert testimony, and use of documents by a witness. The court found no reversible error, determining either that the disputed evidence was admissible under exceptions to hearsay or that the appellant failed to demonstrate prejudice. The court also concluded that the cumulative-error argument was not preserved for review. After conducting its required review for additional prejudicial error, the Supreme Court of Arkansas affirmed the convictions and sentences imposed by the circuit court. View "TATE v. STATE OF ARKANSAS" on Justia Law

James Ray Davis pleaded guilty in 2017 to several charges, including commercial and residential burglary. Later, while incarcerated, Davis filed a pro se petition for writ of habeas corpus in the county of his incarceration. In his petition, Davis asserted that his guilty plea was induced by prosecutor deception, ineffective assistance of counsel, and trial court misconduct. He also alleged constitutional and due process violations. The petition included affidavits that were difficult to interpret, and although Davis used a form referencing Arkansas Code Annotated section 16-112-201, he did not claim actual innocence or request scientific testing.The Jackson County Circuit Court treated Davis’s petition as seeking habeas relief under sections 16-112-101 to -123, since he neither stated a claim under section 16-112-201 nor filed the petition in the county of conviction as required for claims based on new scientific evidence. The circuit court denied Davis’s petition, concluding that he failed to state a cognizable action for the writ to issue. Specifically, the court found that Davis did not provide a sentencing order showing the alleged illegality of his sentence and did not demonstrate either facial invalidity of the judgment or lack of circuit court jurisdiction.The Supreme Court of Arkansas reviewed the case and applied the clearly erroneous standard to the circuit court’s ruling. The court held that Davis failed to establish a basis for habeas relief because he did not show that the judgment was invalid on its face or that the circuit court lacked jurisdiction. Without the sentencing order or proof of illegality, the Supreme Court of Arkansas affirmed the circuit court’s denial of Davis’s petition. View "DAVIS v. STATE OF ARKANSAS" on Justia Law