Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree murder, for which he was sentenced to life imprisonment, holding that the trial court did not abuse its discretion by not giving a jury instruction on second-degree murder, a lesser-included offense of first-degree murder.Defendant was charged with first-degree murder for fatally shooting his wife. The trial court denied Defendant's request to instruct the jury on second-degree murder, finding that there was no evidence that Defendant intended anything but to purposely take his wife's life. On appeal, Defendant argued that the trial court abused its discretion by not instructing the jury on second-degree murder. The Supreme Court affirmed, holding that there was no rational basis for giving the instruction, and therefore, the trial court did not err. View "Marshall v. State" on Justia Law

The Supreme Court affirmed the dismissal of Appellant's pro se civil rights complaint filed pursuant to the Arkansas Civil Rights Act of 1993 (ACRA), Ark. Code Ann. 16-123-101 to -108, in which he alleged that Arkansas Department of Correction (ADC) officials violated his constitutional rights, holding that the circuit court did not err in dismissing the complaint.Appellant sued Appellees in their official and individual capacities, alleging that they had violated his constitutional rights to free speech, free exercise of his religion, access to the court, due process, and equal protection. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that Appellees were immune from liability because Appellant failed to raise claims that demonstrated the deprivation of a constitutional right. View "Muntaqim v. Payne" 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 error coram nobis alleging that he was denied effective counsel prior to his criminal trial and that this violation of his Sixth Amendment right entitled him to coram nobis relief, holding that Petitioner was not entitled to relief.Petitioner was convicted of two counts of capital murder and one count of second-degree murder and sentenced to life imprisonment without parole on the capital murder charges. Petitioner later filed his coram nobis petition, raising claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner's allegations of ineffective assistance of counsel did not support issuance of the writ of error coram nobis. View "Hall v. State" 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 Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. In his petition for writ of habeas corpus, Appellant appeared to challenge the validity of the statute pertaining to the offense of first-degree murder, the arrest warrant, the information, and the entry of the judgment of conviction. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant did not state grounds on which a writ of habeas corpus could issue. View "Fuller/Akbar v. Payne" on Justia Law

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