Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for a writ of mandamus that sought to compel the disclosure of documents under the Freedom of Information Act (FOIA), Ark. Code Ann. 25-19-105 to -110, holding that the circuit court did not err in denying the petition.Appellant was convicted of capital murder and aggravated robbery and sentenced to life imprisonment without parole. The Supreme Court affirmed. In his FOIA petition, Appellant argued that he was entitled to materials from the prosecutor and the Hot Springs Police Department connected to his criminal conviction. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to show that he had an established legal right to access investigative materials from local authorities. View "Burgie v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for a writ of habeas corpus filed in the county of his incarceration, holding that Appellant failed to demonstrate that he was entitled to issuance of the writ.Appellant pleaded guilty to two counts of capital murder and was sentenced to life imprisonment without the possibility of parole. In his habeas corpus action, Appellant argued that because there was no record of the guilty proceedings to support what was contained in the judgment and commitment order, his judgment and commitment order was invalid on its face. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to state a basis for issuance of the writ. View "True v. Payne" on Justia Law

The Supreme Court reversed the order of the circuit court denying mother's motion to prohibit the Arkansas Department of Human Services (ADHS) from immunizing her one-year-old daughter, M.S., over her objection after the circuit court adjudicated M.S. dependent-neglected, holding that Mother properly availed herself of the vaccination exemption provided for by Ark. Code. Ann. 6-18-702.On appeal, Mother argued that ADHS, as the temporary custodian of M.S., did not have the authority to immunize the child over her philosophical and religious objections. The Supreme Court reversed, holding (1) under the circumstances, the legal issues were sufficiently developed to allow an intelligent and useful decision, and therefore, the case was ripe for appellate review; and (2) Mother exercised her right to exempt M.S. from immunization, as was her right as a parent. View "Macklin v. Arkansas Department of Human Services" on Justia Law

The Supreme Court answered a certified question in the negative and held that Ark. Code Ann. 27-34-106(a) does not violate the separation of powers doctrine under article 4, section 2, and Amendment 80, section 3 of the Arkansas Constitution.The underlying wrongful death and survival action arose from an accident in which Defendants negligently caused a vehicle collision. A two-year-old girl, who was in the cab of a pickup at the time of the accident and was not restrained in a child safety seat, was killed. Defendants asserted fault on the part of the driver of the pickup truck. Plaintiff then filed a motion for partial summary judgment with respect to comparative fault and nonparty fault related to child-safety restraint nonuse, arguing that the defense was precluded as a matter of law by section 27-34-106(a). The Supreme Court answered a certified question about the issue, holding that section 27-34-106(a) - a legislative pronouncement that failing to use a child-safety seat is not a negligent act and therefore cannot be used to compare the injured plaintiff's fault to the fault of the defendant - is more substantive than procedure and does not constitute a violation of the separation of powers doctrine. View "Edwards v. Thomas" on Justia Law

The Supreme Court denied Petitioner's petition to proceed in forma pauperis with respect to a petition for writ of certiorari, holding that Petitioner was not entitled to relief.Petitioner, proceeding pro se, submitted a complaint to the Judicial Discipline and Disability Commission concerning the circuit judge who presided at his criminal trial. Petitioner then tendered a petition for writ of certiorari to complete the record and to review the Commission's disposition of the complaint with the petition to proceed in forma pauperis seeking file the petition for writ of certiorari without remitting the required filing fee. The Supreme Court denied the petition, holding that where no fundamental right was involved, the filing fees did not violate due process. View "Burnside v. Arkansas Judicial Discipline & Disability Commission" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's claim for habeas relief on the grounds that Petitioner's allegations should have been raised at trial or in a timely petition under Ark. R. Crim. P. 37.1, holding that Petitioner failed to raise a claim for issuance of the writ.Petitioner was convicted of capital murder and sentenced to a term of life imprisonment without parole. The Supreme Court affirmed. Petitioner later filed his habeas corpus petition, arguing that his conviction was void because he was tried by an eleven-member jury. The circuit court dismissed the action. The Supreme Court affirmed, holding that Petitioner's claim constituted a due process claim that was not cognizable in a habeas proceeding and should have been raised on direct appeal or in a petition for postconviction relief. View "Phillips v. Culpepper" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying the motion to dismiss this action against the Arkansas Department of Education, members of the Arkansas State Board of Education, and the Commissioner of Education (collectively, the State Board), holding that the circuit court correctly denied sovereign immunity on the constitutional delegation of authority claim.Several parents and grandparents of students in the Little Rock School District brought this lawsuit challenging the State Board's continued control of LRSD through limitations placed on a new school board. The State Board filed a motion to dismiss based on sovereign immunity and lack of subject matter jurisdiction. The circuit court denied the motion to dismiss. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court lacked subject matter jurisdiction over Plaintiffs' Administrative Procedure Act claim; (2) Plaintiffs failed to sufficiently plead an illegal-acts or ultra vires exception to sovereign immunity under Ark. Code Ann. 6-15-2917(c); and (3) the circuit court properly denied sovereign immunity on Plaintiffs' constitutional delegation of authority claim because the sufficiently pled challenge to the constitutionality of Ark. Code Ann. 6-15-2916 and -2917 overcame sovereign immunity. View "Arkansas Department of Education v. McCoy" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant stated no ground on which the writ could issue.Appellant entered a plea of nolo contenders to manslaughter and false imprisonment. Appellant was sentenced as a habitual offender to twenty years' imprisonment for manslaughter and ten years' suspended imposition of sentence for false imprisonment. Appellant later filed a habeas petition contending that the felony information in his case was insufficient because it did not charge him with being a habitual offender. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant failed to establish that the trial court lacked jurisdiction in his case. View "Johnson v. Payne" on Justia Law

The Supreme Court dismissed this interlocutory appeal brought by the State challenging a sanctions order entered by the circuit court pursuant to Ark. R. Civ. P. 37, holding that this Court lacked appellate jurisdiction over the appeal.The Arkansas Attorney General brought this action in the name of the State against several pharmaceutical companies in connection with Defendants' role in the ongoing opioid epidemic. During the proceedings, the circuit court found that the Attorney General had not provided complete and specific discovery responses, in violation of the court's discovery orders, and then entered an order sanctioning the Attorney General. The Attorney General appealed. The Supreme Court dismissed the appeal, holding that the sanctions order was not a final or otherwise appealable order under Ark. R. App. P.-Civ. 2(a)(4). View "State ex rel. Rutledge v. Purdue Pharma L.P." 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 a writ of error coram nobis, holding that Petitioner failed to allege sufficient grounds for the issuance of the writ.Petitioner was convicted of rape and theft of a van. In the coram nobis petition at issue, Petitioner alleged that the prosecutor withheld DNA evidence derived from a vaginal swab taken from the victim and that the DNA evidence was material. Petitioner also filed two motions in connection with the coram nobis petition. The Supreme Court denied the petition, which rendered moot the motions, holding that Petitioner was not entitled to relief. View "Makkali v. State" on Justia Law