Justia Arkansas Supreme Court Opinion Summaries
Lee v. Payne
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
Herron v. Ark. Dep’t of Corrections
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
Posted in:
Criminal Law
Break v. State
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
Posted in:
Criminal Law
Hendrix v. Municipal Health Benefit Fund
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
May v. State
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
Posted in:
Criminal Law
Herron v. Ark. Department of Corrections
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
Posted in:
Civil Rights, Criminal Law
Curran v. Ark. Client Security Fund
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
Posted in:
Criminal Law, Government & Administrative Law
Howard v. Baptist Health
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
Posted in:
Personal Injury, Trusts & Estates
Hackie v. Bryant
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
Gibson v. Buonauito
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
Posted in:
Civil Procedure