Justia Arkansas Supreme Court Opinion Summaries

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

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

The Supreme Court affirmed the circuit court's denial and dismissal of Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in dismissing the petition.Appellant was convicted of two counts of aggravated robbery and sentenced to two consecutive terms of 240 months' imprisonment. The court of appeals affirmed. In his pro se petition for writ of habeas corpus, Appellant asserted that the trial court lacked jurisdiction to convict and sentence him on two separate counts of aggravated robbery, and therefore, he was illegally detained without lawful authority. The trial court dismissed the petition. The Supreme Court affirmed, holding that Petitioner failed to show that the trial court lacked jurisdiction or that the commitment order was invalid on its face. View "Johnson v. Payne" on Justia Law

The Supreme Court affirmed Defendant's convictions of capital murder and his sentence of life imprisonment without parole, holding that there was no error or abuse of discretion in the proceedings below.On appeal, Defendant argued that there was insufficient evidence to support his convictions and that several of the circuit court's evidentiary rulings were in error, requiring reversal. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to support Defendant's conviction for premeditated and deliberated capital murder; and (2) Defendant's argument that the circuit court erroneously admitted several pieces of evidence over his authentication and hearsay objections was unavailing. View "Keesee v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition to partially seal his criminal record, holding that there was no error.Petitioner was charged with several crimes. In 2010, pursuant to a plea agreement, the capital-murder charge was reduced to first-degree murder and the kidnapping and burglary charges were nolle pressed. Petitioner then pleaded guilty to one count each of first-degree murder, aggravated assault, and attempting to furnish a prohibited article. In 2020, Petitioner filed a petition pursuant to Ark. Code Ann. 16-90-1410 to seal the nolle prossed charges. The trial court denied the petition on the ground that 16-90-1410 limited the court's authority to partially seal a record. The Supreme Court affirmed on de novo review, holding that section 16-90-1410, which became effective in 2014, was not applicable to the charges Petitioner sought to have sealed. View "Gonder v. State" on Justia Law

The Supreme Court reversed the judgment of the Arkansas Workers' Compensation Commission denying Appellant's claim for additional medical benefits, holding that the Commission erred in determining that Appellant's claim for additional medical benefits was barred by the statute of limitations.In 2015, Appellant was injured while working for Liberty Trailer and sustained a compensable right-shoulder injury. In 2019, Appellant requested additional benefits. An administrative law judge found that the claim was barred by the statute of limitations. The Commission affirmed. The Supreme Court reversed, holding that, under a plain reading of Ark. Code Ann. 11-9-702(b)(1), Appellant's claim for additional medical benefits was timely. View "Wynne v. Liberty Trailer" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellants' motion for an emergency injunction that sought the removal of three members of the Eureka Springs City Advertising and Promotion Commission (CAPC), holding that there was no error.On appeal, Appellants argued (1) Carol Wright's appointment to the CAPC violated Ark. Const. art. 19, 3, and (2) the appointments of Melissa Green and Harry Meyer to the CAPC violated Ark. Code Ann. 14-4-107(a)(2). The Supreme Court affirmed, holding (1) the circuit court correctly concluded that Wright's CAPC appointment was not constitutionally prohibited; and (2) the circuit court did not err when it determined that Green and Meyer were qualified to serve as CAPC commissioners despite being sitting council members at the time of their appointments. View "Johnson v. Wright" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for a writ of habeas corpus, holding that the circuit court did not err in dismissing the petition.Appellant pled guilty to the unlawful discharge of a firearm and first-degree battery. In his habeas petition, Appellant argued that his sentence for discharge of a firearm from a vehicle was illegal on its face because it should have been listed as a Class B felony rather than as a Class Y felony. The circuit court concluded that Appellant's claim for habeas relief lacked merit. The Supreme Court affirmed, holding that Appellant failed to show that he was entitled to habeas corpus relief. View "Rawls v. Gray" on Justia Law

The Supreme Court reversed the order of the circuit court granting a preliminary injunction in favor of Plaintiffs, holding that the grounds on which the trial court relied in entering the preliminary injunction had become moot.Plaintiffs were five Arkansas residents who had been receiving pandemic-related unemployment benefits through Pandemic Unemployment Assistance, Federal Pandemic Unemployment Compensation, and Pandemic Emergency Unemployment Compensation prior to the State's termination of its participation in these programs. Plaintiffs sought declaratory and injunctive relief, alleging that Defendants - Governor Asa Hutchison and Arkansas Division of Workforce Services Director Charisse Childers - lacked the authority under Ark. Code Ann. 11-10-312 to terminate the State's participation in the programs. The trial court granted Plaintiffs' motion for a preliminary injunction ordering Defendants to reengage in the terminated programs. The Supreme Court reversed, holding that the grounds for the preliminary injunction had been rendered moot by the General Assembly's passage of Act 1 of the First Extraordinary Session of 2021. View "Hutchinson v. Armstrong" on Justia Law

The Supreme Court granted Petitioner's pro se petition for writ of mandamus in which he asserted that Honorable Marcia Hearnsberger, a circuit judge, had not ruled on a pro se motion seeking a nunc pro tunc order in which Petitioner claimed that a sentencing order required correction of a clerical error, holding that Petitioner was entitled to the request.Petitioner stated that he filed the mandamus action because the circuit court had not ruled on his underlying motion seeking a nunc pro tunc order. The Supreme Court granted the petition, holding that Petitioner was entitled to the relief he sought. View "Golden v. State" on Justia Law