Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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

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

The Supreme Court denied Petitioner's pro se fourth petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that the petition failed to contain facts that would support a cognizable claim for issuance of the writ.Petitioner was found guilty of residential burglary and rape and sentenced as a habitual offender to an aggregate term of 900 months' imprisonment. At issue on appeal was the denial of Petitioner's fourth pro se coram nobis petition, in which he alleged that the State falsified or failed to disclose evidence against him. The court of appeals affirmed. The Supreme Court affirmed, holding that Petitioner did not meet the criteria for granting the petition. View "Noble v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying John Thurston's motion to dismiss this action based on sovereign immunity, holding that Thurston was not entitled to sovereign immunity.Plaintiffs, the League of Women Voters of Arkansas and Arkansas United and several individuals, filed suit against Defendants, including Thurston in his official capacity as the Secretary of State, alleging that four acts passed by the 93rd Session of the Arkansas General Assembly were unconstitutional. Thurston filed a motion to dismiss based on sovereign immunity, which the circuit court granted. The Supreme Court affirmed, holding that Thurston was not entitled to sovereign immunity under the facts of this case. View "Thurston v. League of Women Voters of Ark." on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by Appellees - Arkansas Parole Board, John Felts, and Andy Shock - in Appellant's action filed pursuant to the Administrative Procedure Act (APA), Ark. Code Ann. 25-15-201 through 25-15-220, holding that Appellant failed to state a sufficient basis for judicial review under the APA.Appellant pleaded guilty to the sexual abuse of a fifteen-year-old and was sentenced to thirty years' imprisonment. Years later, the parole board denied Appellant parole for a two-year period of time. Appellant filed a petition for judicial review from the denial of his parole under the APA, alleging that Appellees failed to adhere to parole statutes and the APA, in violation of his due process rights. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion when it dismissed Appellant's complaint for failing to state a claim for relief pursuant to the APA. View "Wood v. Arkansas Parole Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for a copy of his trial transcript at public expense, holding that the circuit court properly concluded that Appellant had failed to demonstrate a compelling need for a copy of his trial transcript.Appellant was found guilty of two counts of aggravated robbery and one count of theft of property and sentenced as a habitual offender to life imprisonment. In his motion filed in the trial court Appellant requested copies of his trial transcript from his criminal case at public expense. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant failed to demonstrate a compelling need for relief. View "Spearman v. State" on Justia Law