Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's pro se petition for writ of habeas corpus, holding that Appellant was not entitled to relief.Appellant was convicted of six felony offenses, including aggravated residential burglary. In his habeas petition, Appellant alleged that his judgment of conviction was void because the trial judge failed to sign the sentencing order, in contravention of Arkansas Supreme Court Administrative Order No. 8. The circuit court dismissed the claim on the grounds that Appellant's sentencing order was electronically signed and filed in compliance with Administrative Order No. 21. The Supreme Court affirmed, holding that Appellant's claim constituted an assertion of trial error that was not cognizable in habeas proceedings. View "Thompson v. Payne" on Justia Law

The Supreme Court denied Petitioner's petitions for writ of habeas corpus, to reinvest jurisdiction in the trial court to consider a writ of error coram nobis, and to recall the mandate, holding that Petitioner was not entitled to relief.Petitioner was convicted of capital murder in furtherance of aggravated robbery and sentenced to life imprisonment without the possibility of parole. The Supreme Court affirmed on appeal. Petitioner subsequently filed the petitions at issue on appeal, making several claims. The Supreme Court denied Petitioner's petitions for habeas relief, coram nobis relief, and to recall the mandate, holding that none of Petitioner's claims had merit. View "Wells v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second petition and amended second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claim did not establish a ground for issuance of the writ.Petitioner was convicted of first-degree murder, kidnapping, and aggravated assault. The Supreme Court affirmed. Petitioner later brought a pro se second petition and an amended second petition to reinvest jurisdiction jurisdiction in the trial court to consider a writ of error coram nobis, asserting that the State withheld evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petitions, holding that Petitioner's claims did not entitle him to relief. View "Williams v. State" on Justia Law

The Supreme Court affirmed the circuit court's order granting Father's motion for modification of custody of the parties' daughter, holding that the court did not err in modifying the previous custody order after finding that Father's change in employment and move to Little Rock constituted a material change in circumstances.A previous order of the circuit court awarded joint custody of the child to the parties and provided a specific visitation schedule. Father later filed an amended complaint for contempt and for modification. The circuit court found that Mother was not in contempt of court but concluded that Father's change in employment and move to Little Rock constituted a material change in circumstances that warranted modification of child custody to grant Father equal time with the child. The Supreme Court affirmed, holding that the circuit court's decision to reallocate time was not an abuse of discretion. View "Nalley v. Adams" on Justia Law

The Supreme Court dismissed this appeal for lack of a final or otherwise appealable order, holding that the orders Appellants were attempting to appeal were not appealable on an interlocutory basis.In this class-action dispute brought against certain online travel companies (the OTCs) Appellees alleged that the OTCs failed to remit the full amount of taxes imposed by the appellee government entities on hotel accommodations. The circuit court granted Appellees' motion for summary judgment. Appellees then filed an amended and supplemental complaint requesting, in light of the declaratory judgment determination, a judgment against the OTCs for all unpaid taxes from 1995 to the present, plus penalties and interest. The circuit court denied the OTCs' combined motion to dismiss and strike Plaintiffs' second amended complaint. The Supreme Court dismissed the appeal, holding that the order was not appealable. View "Hotels.com, L.P. v. Pine Bluff Advertising & Promotion Commission" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of coram nobis, holding that none of Petitioner's claims established grounds for the writ.Petitioner pleaded guilty to four counts of rape and nolo contendere to one count of rape. On appeal, Petitioner argued that the trial judge was biased at his resentencing hearing and should have recused himself or, alternatively, that the trial court should have permitted him to withdraw his guilty and nolo contendere pleas. The Supreme Court affirmed. In his coram nobis petition, Petitioner sought relief both for the alleged coercion of his pleas and for the trial judge's failure to recuse himself. The Supreme Court denied relief, holding that Petitioner's claims did not entitle him to coram nobis relief. View "Walls v. State" on Justia Law

The Supreme Court denied Petitioner's pro se second 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 convicted of two counts of the rape of his biological daughters. Petitioner later filed a petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis based on affidavits executed by his daughters that recanted their trial testimony. The Supreme Court denied the petition, holding that Petitioner failed to establish that the State violated Brady v. Maryland, 373 U.S. 83 (1963) and otherwise failed to establish sufficient grounds for issuance of the writ. View "White v. State" on Justia Law

The Supreme Court reversed the circuit court's order finding that both Rule 2.13(b)(5) of the Casino Gaming Rules and Ark. Code Ann. 27-117-101(b) are unconstitutional, holding that the circuit court erred.In 2019, the Arkansas Racing Commission (ARC) adopted Rule 2.13(5)(b) (the Rule) of the ARC-Casino Gaming Rules, which provides that letters of support must be from the county judge, quorum court, or mayor holding office at the time of the submission of an application for a casino license. The General Assembly subsequently passed Act 371 of 2019 (the Act), which was identical to Rule 2.13(5)(b) and is codified at Ark. Code Ann. 23-117-101. Appellant applied for a casino license in May 2019, but the application was denied. Appellant filed the underling litigation challenging the denial of a license and the constitutionality of the Act. The circuit court declared that Rule and the Act were unconstitutional because they imposed an additional qualification to Arkansas Constitutional Amendment 100. The Supreme Court reversed, holding (1) the Rule is consistent with Amendment 100 and does not impose an additional requirement; and (2) the Act is consistent with Amendment 100 and does not impose an additional requirement. View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law

The Supreme Court reversed the order of the circuit court reversing the determination of an Arkansas Department of Human Services (DHS) administrative law judge (ALJ) that allegations of child maltreatment made against Steven Mitchell were true and that Mitchell should be listed on the Arkansas Child Maltreatment Central Registry, holding that the circuit court erred.In reversing the DHS's determination, the circuit court concluded that the agency decision was based on unlawful procedures and a violation of Mitchell's due process rights. The Supreme Court reversed, holding (1) the DHS's failure to follow its own statutory notice procedures violated Mithcell's statutory rights when DHS placed his name on the maltreatment registry in 2004, but the DHS's earlier failures did not vitiate the 2018 agency decision at issue on review; and (2) substantial evidence supported the DHS's decision, and before the decision was made Mitchell received the required notice, he had an opportunity for a meaningful hearing, and his substantial rights were not prejudiced. View "Arkansas Department of Human Services Crimes Against Children Division v. Mitchell" on Justia Law

The Supreme Court denied Petitioner's second pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis and seeking the appointment of postconviction counsel, holding that Petitioner failed to raise a cognizable claim for issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to a term of life imprisonment plus a term of 180 months. The Supreme Court affirmed. In the instant coram nobis petition, Petitioner argued that he was entitled to relief due to a coerced guilty plea, the failure of the prosecutor or his counsel to advise him of the spousal privilege in violation of Brady v. Maryland, 373 U.S. 83 (1963), and ineffective assistance of both trial counsel and postconviction counsel. The Supreme Court denied the writ and denied Petitioner's motion for appoint of counsel as moot, holding that Petitioner's claims were not cognizable in a coram nobis proceeding. View "Gordon v. State" on Justia Law