Justia Arkansas Supreme Court Opinion Summaries
McArty v. State
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis in his criminal case and his motion for appointment of counsel, holding that Petitioner failed to establish sufficient grounds for issuance of the writ.In his coram nobis petition, Petitioner argued that the State violated Brady v. Maryland, 373 U.S. 83 (1963), by concealing from him the full contents of his criminal case file. The Supreme Court denied the petition, holding that Petitioner failed to overcome the presumption that the judgment of conviction was valid. View "McArty v. State" on Justia Law
Posted in:
Criminal Law
Henderson v. Payne
The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's pro se petition for a writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101 to -123, holding that Appellant's allegations were not cognizable in a habeas proceeding.Appellant, who was incarcerated for aggravated robbery, filed a habeas petition alleging that the trial court placed supervisory conditions on his suspended sentence that controverted the suspended sentence into an illegal imposition of probation after the completion of a term of imprisonment. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was being illegally detained within the circuit court's jurisdiction. View "Henderson v. Payne" on Justia Law
Posted in:
Criminal Law
Rutledge v. Remmel
In this interlocutory appeal, the Supreme Court reversed and dismissed in part and dismissed in part this appeal from the judgment of the circuit court in a dispute centering on the Attorney General's spending on television commercials and legal filings in out-of-state federal litigation, holding that dismissal was warranted.In this lawsuit, Plaintiffs alleged that Attorney General Leslie Rutledge exceeded her authority and should be enjoined from continuing to act in excess of her authority and that she had spent funds in excess of her authority in an illegal exaction. The Attorney General asserted various immunity defenses, which the circuit court denied. The Supreme Court reversed and dismissed in part and dismissed in part, holding (1) as to the first claim for relief, the Attorney General had sovereign immunity and could not be enjoined; and (2) as to the second allegation, Rutledge as an individual was entitled to statutory immunity. View "Rutledge v. Remmel" on Justia Law
Posted in:
Civil Procedure, Government & Administrative Law
Bentonville School District v. Sitton
The Supreme Court reversed the order of the circuit court enjoining the enforcement of the Bentonville School District's mask policy in favor of Plaintiffs, parents of school children, holding that the the circuit court abused its discretion in granting Plaintiffs' motion for a temporary restraining order (TRO).In granting the TRO, the circuit court concluded that the school policy at issue violated Plaintiffs' right under Ark. Const. art. II, 21 and 29 to care for their children and that the District lacked the authority to issue the mask policy. The Supreme Court reversed, holding that (1) the circuit court abused its discretion in finding that the policy violated Plaintiffs' constitutional rights and was enacted without proper authority; and (2) Plaintiffs failed to show that irreparable harm would result in the absence of a TRO. View "Bentonville School District v. Sitton" on Justia Law
Steinbuch v. University of Arkansas
The Supreme Court affirmed in part and dismissed in part the orders of the circuit court denying Appellant's motion for an order to waive record fees and Appellant's motion to be determined the prevailing party in a lawsuit brought pursuant to the Freedom of Information Act (FOIA), holding that there was no error or abuse of discretion.One appeal in this case related to Appellant's efforts to be declared a prevailing party in his FOIA action against the University of Arkansas, and the second was an order denying his motion to waive record fees. The circuit court dismissed the FOIA claim with prejudice because the parties had negotiated a settlement as to that claim. In denying the motion at issue, the circuit court found it to be improper and untimely. The Supreme Court (1) dismissed Appellant's appeal as to his motion for an order to waive fees as not final and appealable; and (2) affirmed the order of the circuit court denying the motion for determination of prevailing party, holding that the circuit court based its decision on independent and alternative grounds, and Appellant failed to challenge them both. View "Steinbuch v. University of Arkansas" on Justia Law
Posted in:
Communications Law
Boyd v. Payne
The Supreme Court affirmed the decision of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ.After a jury trial, Appellant was convicted of aggravated robbery and theft of property. In his pro se petition for writ of habeas corpus Appellant argued that a different standard of review should be applied to habeas cases, he was actually innocent, his constitutional rights were violated, and the evidence was insufficient to sustain his conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for issuance of the writ or that the circuit court erred by denying habeas relief. View "Boyd v. Payne" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Trammel v. Payne
The Supreme Court affirmed the judgment of the circuit court denying Appellant's second petition for a writ of habeas corpus, holding that Appellant's second petition was an abuse of the writ.Appellant pleaded nolo contendere to multiple felony counts in three separate criminal cases. In his first habeas petition, Appellant alleged that the sentences in two cases were illegal because a habitual-offender enhancement was improperly imposed. The circuit court denied the petition. In his second habeas petition, Appellant raised the same arguments he raised in the circuit court. The circuit court denied the petition. The Supreme Court affirmed, holding that the circuit court did not err in denying the petition. View "Trammel v. Payne" on Justia Law
Posted in:
Criminal Law
Morgan v. Payne
The Supreme Court affirmed the circuit court's judgment denying and dismissing Appellant's pro se petition for a writ of habeas corpus, holding that Appellant's claim lacked factual support and failed to demonstrate entitlement to the writ.Appellant entered a guilty plea to rape and sexual assault in the first degree. Appellant subsequently filed several petitions for habeas relief. In the habeas petition at issue before the Supreme Court Appellant alleged that he was convicted twice for the same offense, in violation of the constitutional prohibition against double jeopardy. The Supreme Court denied relief, holding that Appellant's claim lacked merit. View "Morgan v. Payne" on Justia Law
Posted in:
Criminal Law
Funding Metrics, LLC v. Letha’s Pies, LLC
The Supreme Court reversed the circuit court's order granting class certification in this action brought by Letha's Pies, LLC and Rhonda and Timothy Glenn, on behalf of themselves and all others similarly situated (collectively, Letha's Pies), for alleged violations of the Arkansas Securities Act, holding that the circuit court abused its discretion by refusing to enforce a class-action waiver.Letha's Pies entered into a merchant agreement to sell Funding Metrics, LLC $21,900 of Letha's Pies' future receivables in exchange for an immediate payment of $15,000 by Funding Metrics. The agreement contained a class-action waiver provision. Letha's Pies subsequently brought a class-action complaint claiming that Funding Metrics promoted and sold securities in violation of Arkansas law. Funding Metrics moved to dismiss based on the class-action waiver. The circuit court denied the request, finding that the agreement lacked mutuality of obligation. The circuit court then certified two classes. The Supreme Court reversed, holding that the circuit court abused its discretion by refusing to enforce the class-action waiver in the merchant agreement as a bar to class certification. View "Funding Metrics, LLC v. Letha's Pies, LLC" on Justia Law
Posted in:
Class Action, Securities Law
Grant v. Payne
The Supreme Court affirmed the order of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in dismissing the habeas petition.Appellant was convicted of capital murder and first-degree battery and sentenced to life in prison. In his habeas petition, Appellant argued that his capital murder conviction was illegal because his sentence exceeded the maximum sentence for the crime designated in his arrest warrant of first-degree murder. The circuit court dismissed the claim. The Supreme Court affirmed, holding that the circuit court did not clearly err by denying and dismissing Appellant's petition for habeas relief. View "Grant v. Payne" on Justia Law
Posted in:
Criminal Law