Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the circuit court did not err in denying relief.In denying and dismissing Appellant's petition, the circuit court found that the criminal information in this case was not deficient and that Appellant's counsel provided effective assistance. The Supreme Court affirmed, holding that, contrary to Appellant's contention on appeal, the criminal information complied with Ark. Const. art. VII, 49. View "Halliburton v. State" on Justia Law

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The Supreme Court reversed the order of the circuit court denying Bayer Cropscience, LP's motion to intervene in a lawsuit challenging a rule adopted by the Arkansas State Plant Board, holding that the circuit court erred in denying Bayer's motion to intervene as a matter of right.Plaintiffs filed a complaint seeking a declaratory judgment that the Plant Board violated the Administrative Procedure Act (APA) by adopting the 2021 Dicamba Rule. Bayer, which manufactures and sells the herbicide Dicamba, moved to intervene in the action. The circuit court denied the motion. The Supreme Court reversed, holding that Bayer was entitled to intervene as a matter of right because it satisfied all of the requirements set forth in Ark. R. Civ. P. 24. View "Bayer Cropscience, LP v. Hooks" on Justia Law

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The Supreme Court reversed the order of the circuit court that granted Appellant's mandamus petition alleging that the Arkansas Department of Correction had miscalculated his parole eligibility, holding that Appellant was entitled to a parole-eligibility calculation for his enhanced sentence.At issue was the calculation of Defendant's parole eligibility in connection with his sentence of 180 months' imprisonment for a use of a firearm in the commission of a felony offense. Relying on the amended version of Ark. Code Ann. 16-90-120(e), the circuit court determined that the offense of aggravated robbery and the enhancement based on the use of a firearm were separate for purposes of determining parole eligibility. The Supreme Court reversed, holding that Defendant was entitled to a parole-eligibility calculation for the enhanced sentence pursuant to the statutes in effect when he committed aggravated robbery. View "Rogers v. Arkansas Department of Correction" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111(a), holding that Appellant failed to established that his sentence was imposed in an illegal manner.Appellant was sentenced for murder in the first degree and attempted murder in the first degree to a total of 600 months' imprisonment. Appellant later brought this petition arguing that his sentences should be vacated because they exceeded the presumptive sentences allowed for the offenses and because he was not afforded due process. The Supreme Court denied relief, holding that Appellant's sentences were facially legal. View "Hall v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the circuit court to allow him to file a petition for writ of error coram nobis, holding that Petitioner failed to state a ground on which the writ could issue.Petitioner was convicted of arson and sentenced as a habitual offender to 480 months in prison. In his petition, Petitioner argued that the record contained misinformation concerning two prior convictions that affected his eligibility for parole. The Supreme Court denied the petition, holding that Petitioner did not allege any recognized reason for coram nobis relief. View "Jones v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the trial court ordering disclosure of the documents requested by Russell R. Racop under the Arkansas Freedom of Information Act (FOIA), Ark. Code Ann. 25-19-101 et seq., holding that the trial court erred in finding that the requested documents were not exempt from FOIA under Ark. Code Ann. 25-19-105(b)(10).Racop sent an email request for public records to the Arkansas State Police and its director and the attorney for the Arkansas Department of Public Safety/Arkansas State Police (collectively, ASP), which ASP denied. Racop then brought this action seeking an order requiring disclosure under FOIA. The trial court granted the request. The Supreme Court reversed, holding that Racop's request was exempt from disclosure under section 25-19-105(b)(10)(a). View "Arkansas State Police v. Recop" on Justia Law

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The Supreme Court affirmed the trial court's judgment denying Appellant's petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that Appellant's claims lacked merit.Appellant was convicted of capital murder and sentenced as a habitual offender to life imprisonment without parole. In his postconviction petition, Appellant argued, among other things, that his counsel provided ineffective assistance. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his allegations of error. View "Thomas v. State" on Justia Law

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The Supreme Court reversed the order of the circuit court acquitting Defendant by reason of mental disease or defect of one count of theft of property and two counts each of kidnapping and first-degree false imprisonment of two minors, holding that the circuit court erred by failing to require Defendant to register as a sex offender.The State charged Defendant with theft of property and first-degree false imprisonment. The circuit court concluded that Defendant should be acquitted due to lack of criminal responsibility and found that Defendant should not be required to register as a sex offender. The State appealed, arguing that the circuit court erred by declining to require Defendant to register as a sex offender. The Supreme Court agreed and reversed, holding that the circuit court erred by not requiring Defendant to register as a sex offender in its judgment of acquittal. View "State v. Scott" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that there were no grounds stated in either the petition filed in the circuit court or in Appellant's appellate arguments on which a writ of habeas corpus could issue.Appellant pleaded guilty to one count of first-degree domestic battery and two counts of second-degree domestic battery. At issue before the Supreme Court was the circuit court's denial of Appellant's second petition for writ of habeas corpus, in which Appellant alleged that the Arkansas Department of Corrections illegally enhanced his sentence. The Supreme Court affirmed, holding that Appellant's sentences did not exceed the maximum penalty for the offenses to which he pleaded guilty, and therefore, the judgment was facially valid. View "Jefferson v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.After a jury trial, Petitioner was convicted of first-degree murder and sentenced to 540 months' imprisonment. In Petitioner's pro se second coram nobis petition Petitioner alleged, among other things, that insufficient evidence supported his conviction and that trial counsel was ineffective. The Supreme Court denied the petition, which rendered Petitioner's motion for appointment of counsel moot, holding that Petitioner's claims were outside the purview of coram nobis proceedings. View "Carroll v. State" on Justia Law

Posted in: Criminal Law