Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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