Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's petition for declaratory relief, holding that Appellant failed to demonstrate that Appellees acted in contravention of the statutes pertaining to his parole eligibility.After a bench trial, Appellant was convicted of first-degree battery and second-degree battery and sentenced to an aggregate term of 264 months' imprisonment. In his petition for declaratory relief Appellant challenged the determination of his parole eligibility by officials with the Arkansas Department of Correction. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in dismissing the declaratory judgment action. View "Harkuf v. Marony" on Justia Law

Posted in: Criminal Law
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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, holding that Petitioner failed to establish sufficient grounds for issuance of the writ.Petitioner was found guilty of theft by receiving and fleeing and sentenced as a habitual offender to thirty-five years' imprisonment. In his coram nobis petition Petitioner raised seven claims for relief. The Supreme Court denied relief, holding that Petitioner's claims either were not cognizable in coram nobis proceedings or were without merit. View "Brown v. State" on Justia Law

Posted in: Criminal Law
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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, holding that none of Petitioner's claims established a ground for the writ.Petitioner was convicted of two counts of capital murder and one count of a terroristic act. Petitioner later brought this coram nobis petition alleging that evidence was withheld by the State in violation of Brady v. Maryland, 373 U.S. 83 (1963), trial court error, and ineffective assistance of counsel. The Supreme Court denied the petition, rendering moot Petitioner's motion for appointment of counsel, holding that Petitioner failed to establish that he was entitled to relief. View "Stephenson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the sentence imposed upon Defendant in connection with his plea of guilty to failure to register as a sex offender and plea of guilty to being a habitual offender, holding that the circuit court did not impose an illegal, fine-only sentence in violation of the habitual offender statute.After accepting Defendant's guilty plea, the circuit court made specific findings for leniency and proclaimed a sentence of only a $10,000 fine and no incarceration. The Supreme Court affirmed, holding (1) a plain reading of the statute in effect at the time Defendant committed the crime permitted the circuit court to impose a fine, imprisonment, or both; and (2) the circuit court did not err in imposing a fine-only sentence. View "State v. Mason" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's convictions on three counts of capital murder and felony-firearm enhancement, for which Defendant was sentenced to three consecutive terms of life imprisonment without parole, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the evidence was sufficient to support the verdicts; (2) Defendant was not prejudiced by the circuit court’s handling of a jury note and the replaying of his custodial interview during his absence; (3) Defendant's argument that his defense counsel had a conflict of interest due to prior representation of a State’s witness was without merit based on Defendant's on-the-record statement that he wanted counsel to remain his attorney; and (4) the trial court did not err by denying Defendant's motions to suppress his statements to police. View "Lewondowski v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the circuit court's order reflecting a jury verdict awarding almost $6 million in compensatory damages, jointly and severally, against KBX, Inc. and three KBX individuals (collectively, Appellants) and other defendants and reversed the court's award of attorney's fees, holding that the court erred in part.In this case involving certain farmers' dispute with KBX, a grain exporter and merchandiser, and the KBX individuals over a series of written contracts for the purchase of rice, the circuit court entered a judgment reflecting the jury's award of compensatory damages against Appellants and other defendants. The court assessed attorney's fees and costs against Appellants as a sanction for alleged spoliation of evidence. The Supreme Court reversed in part, holding (1) without any evidence of deceit in the form of a false representation by KBX or the KBX individuals to the farmers, substantial evidence did not support the jury's verdict on deceit; (2) substantial evidence did not support the jury's verdict on constructive fraud or the farmers' conspiracy claim; (3) the circuit court erred as a matter of law in denying Appellants' motion for directed verdict on the farmers' unjust enrichment claim; and (4) remand was required on the issue of attorney's fees for recalculation of an award consistent with this opinion. View "KBX, Inc. v. Zero Grade Farms" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the circuit court denying the State's motion to dismiss and granting a preliminary injunction in favor of Plaintiff, holding that the preliminary injunction was granted erroneously.Plaintiff, a hearing-instrument dispenser whose license was not renewed, brought this action against the Arkansas Department of Health, the Secretary of Health, and Arkansas Board of Hearing Instrument Dispensers, and the Executive Director of the Board of Hearing Instrument Dispensers (collectively, the State), arguing that the Board's refusal to provide him a proper renewal notice and a hearing violated his due process and equal protection rights and was an arbitrary and capricious abuse of the Board's power. The circuit court granted Plaintiff's request for a temporary injunction and declaratory relief. The Supreme Court reversed in part, holding (1) Plaintiff adequately pleaded a due process claim; (2) Plaintiff's equal protection claim was barred by sovereign immunity; and (3) because the preliminary injunction order contained no findings on irreparable harm or likelihood of success on the merits, the case must be remanded for findings in accordance with Ark. R. Civ. P. 65(d)(1). View "Arkansas Department of Health v. Solomon" on Justia Law

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The Supreme Court affirmed the order of the circuit court dismissing Appellant's petition for writ of habeas corpus, holding that there was no error.After a jury trial, Appellant was found guilty of capital murder and aggravated robbery. The court sentenced Appellant as a habitual offender to an aggregate term of life imprisonment without parole. In his habeas corpus petition, Appellant claimed, among other things, that his convictions and sentences were invalid because the prosecutor did not sign the criminal information. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claims for habeas relief. View "Gardner v. Payne" on Justia Law

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The Supreme Court affirmed the circuit court's decision denying Appellant's petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that the circuit court did not clearly err by denying Appellant's petition.Appellant, an inmate serving several sentences, filed his petition to correct an illegal sentence alleging that the sentences imposed in his 2011 convictions and in his revocation were null and void because he was illegally arrested. The circuit court denied the petition, concluding that the petition was without merit. The Supreme Court affirmed, holding that the circuit court's judgment was not clearly erroneous. View "Mister v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus alleging that his conviction was void because his sentences exceeded the maximum statutory sentence for a Class C felony, holding that there was no error.Appellant pled guilty to, among other things, ten counts of possession and distribution of sexually explicit images of children and nineteen counts of possession and distribution of sexually explicit images of children. In his habeas corpus petition Appellant alleged that his conviction was void because his two consecutive sentences for twenty-nine counts of possessing matter depicting sexually explicit images of a child exceeded the maximum statutory sentence for a Class C felony. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's sentence of 240 months’ imprisonment each for ten counts and nineteen counts of possession of matter depicting sexually explicit images of children did not exceed the maximum penalty for those offenses. View "Osburn v. Gray" on Justia Law

Posted in: Criminal Law