Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. Code Ann. 16-90-111, in which he argued that the judgment in his criminal case was facially illegal because his sentence of life imprisonment exceeded the maximum sentence authorized for a Class Y felony, holding that the sentence imposed was not an illegal sentence.In an earlier petition for writ of habeas corpus Appellant raised the same claim that he brought in his petition for postconviction relief. The Supreme Court had concluded that Appellant's life sentence was clearly within the sentencing range for the offense of first-degree murder. As to Appellant's postconviction motion, the Supreme Court denied relief, holding that Appellant was sentenced within the permitted statutory range for first-degree murder, and Appellant failed to establish that the sentence was illegal on its face. View "McArty v. State" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellant's petition for writ of habeas corpus in which he argued that the circuit court erred by not finding that the trial court's impermissible stacking of two statutes resulted in double-penalty enhancement, holding that the sentencing order was incomplete.Appellant pled guilty to third-degree domestic battery and was sentenced as a habitual offender to 144 months' imprisonment. Appellant later brought this habeas petition, alleging that the trial court impermissibly stacked two penalty-enhancement statutes when he was sentenced for felony domestic battery. The circuit court denied the petition. The Supreme Court reversed, holding that the circuit court's decision regarding the facial validity of the sentencing order was erroneous because the trial court did not enter a complete sentencing order. View "Ray v. Payne" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant failed to demonstrate entitlement to Rule 37.1 relief.After a second jury trial, Appellant was convicted of first-degree murder and attempted first-degree murder with a firearm enhancement. The convictions and sentences were affirmed on appeal. Appellant subsequently brought his petition for postconviction relief, alleging ineffective assistance of appellate counsel and pretrial counsel. The trial court denied relief. The Supreme Court affirmed, holding that the trial court did not err by denying the petition without a hearing. View "Sirkaneo v. State" on Justia Law

The Supreme Court denied Appellant's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, for issuance of a writ of habaes corpus, and to correct an illegal sentence, holding that Appellant failed to raise cognizable grounds for coram nobis relief.Appellant was convicted of aggravated robbery and aggravated residential burglary. As grounds for a writ of error coram nobis, alleging that there was insufficient evidence to support the conviction, his counsel provided ineffective assistance, the trial court committed evidentiary error, and he was arrested illegally. The Supreme Court denied the petition, holding that Appellant did not raise cognizable grounds for coram nobis relief and that Appellant failed to proceed with due diligence in bringing his claims. View "Dobbins v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing without prejudice Appellants' claims against Appellees, the Board of Trustees of the University of Arkansas System and others, holding that the circuit court did not err by determining that Appellants lacked standing and that their claims were unripe and nonjusticiable.Appellants, tenured factual members employed by the University of Arkansas System, filed on behalf of themselves and all others similarly situated a complaint against the Board seeking declaratory and injunctive relief based on alleged violations of both federal and state law. The Board filed a motion to dismiss, arguing that claims should be dismissed based on lack of standing, unripeness, and failure to state a claim. The circuit court granted the motion. The Supreme Court affirmed, holding that the circuit court correctly dismissed Appellants' claims. View "Palade v. Board of Trustees" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant's petition for leave to proceed in forma pauperis to pursue a pro se petition for writ of error coram nobis, holding that the circuit court abused its discretion in denying Appellant's request to proceed in forma pauperis when he also filed a coram nobis petition.On appeal, Appellant argued that the circuit court acted arbitrarily and abused its discretion by denying his request to proceed in forma pauperis when he had properly filed his coram nobis petition. The Supreme Court reverse the circuit court's denial of the petition, holding that the circuit court abused its discretion by failing to address the merits of the underlying pro se petition for writ of error coram nobis. View "Randle v. State" on Justia Law

In this case related to a medical marijuana dispensary license the Supreme Court reversed the ruling of the circuit court denying the State's motion to dismiss a complaint seeking temporary and permanent injunctive relief and an injunction enjoining the State form issuing replacement dispensary-facility licenses, holding that the circuit court did not have subject matter jurisdiction over the complaint.In its complaint, Plaintiff, a corporation, alleged that the Medical Marijuana Commission had violated its own rules, the constitution, and the Administrative Procedure Act (APA). The State moved to dismiss on the grounds of sovereign immunity, lack of subject-matter jurisdiction, mootness, and failure to plead facts indicating a cause of action related to equal protection. The circuit court denied the motion. The Supreme Court reversed, holding that the circuit court lacked subject-matter jurisdiction over the complaint under either section 207 or 212 of the APA. View "Arkansas Department of Finance & Administration v. Carroll County Holdings, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus in which he alleged that he was actually innocent of the crimes for which he was convicted, holding that Appellant failed to state a cognizable claim for habeas relief.Appellant was convicted of capital-felony murder with aggravated robbery as the underlying offense and sentenced as a habitual offender to life imprisonment. The Supreme Court affirmed. Appellant later filed this habeas corpus petition, alleging that he was actually innocent of the crimes and also raised multiple allegations of due process violations and trial error. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied Appellant's petition for failure to demonstrate probable cause for issuance of the writ. View "Goodwin v. Payne" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Petitioners' petition for declaratory judgment, writ of mandamus, and request for injunctive relief, holding that the Arkansas Division of Correction wrongfully calculated the parole eligibility on Petitioners' fifteen-year sentence enhancement for committing a felony with a firearm.Petitioners were jointly tried and convicted for their participation in a kidnapping and battery and received differing sentences. Petitioners brought this petition objecting to the Division's calculation of their parole eligibility. The Supreme Court agreed and reversed, holding that parole eligibility for Petitioners should be calculated based on Ark. Code Ann. 16-93-1301. View "Perry v. Payne" on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated robbery and theft of property and his sentence of life in prison as a habitual offender, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that there was insufficient to support his convictions for both crimes and that the circuit court erroneously concluded that his earlier Kansas conviction was comparable for sentencing purposes to an Arkansas serious felony involving violence. The Supreme Court affirmed, holding (1) the evidence was sufficient to support the convictions; and (2) the circuit court did not err in determining that Defendant's Kansas burglary conviction qualified as a prior felony involving violence for sentencing purposes. View "Wright v. State" on Justia Law