Justia Arkansas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to correct an illegal sentence, filed pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to allege facts that supported his claim of an illegal sentence.On appeal, Appellant argued (1) the circuit court lacked authority to impose the sentence; (2) the special prosecutor was not authorized to sign the felony information; (3) the felony information was invalid because it was not signed and did not have an official seal from the clerk; and (4) the jury verdict forms were ambiguous. The circuit court denied relief. The Supreme Court affirmed, holding that the circuit court did not err by denying Appellant's requested relief. View "Rea v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that Appellant failed to demonstrate that his sentence was illegal on its face.Appellant was convicted of rape and sentenced to twenty-five years' imprisonment. Appellant later brought his petition to correct an illegal sentence, arguing that the evidence adduced at trial established that he was guilty of fourth-degree sexual assault. The trial court denied the petition. The Supreme Court affirmed, holding that because Appellant's challenge was to the sufficiency of the evidence, the circuit court did not clearly error when it rejected Appellant's claim for relief. View "Clark v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the judgment of the circuit court denying Defendant's pro se petition to correct an illegal sentence pursuant to Ark. Code Ann. 16-90-111, holding that, as to the suspended imposition of sentences for two counts of first-degree endangerment of a minor, both were statutorily unauthorized and facially illegal.Defendant pleaded guilty to and was convicted of five felony counts and sentenced as a habitual offender. In his petition to correct an illegal sentence, Defendant argued that his sentences were illegal for several reasons. The circuit court denied the petition, concluding that Defendant's claims were untimely and improper. The Supreme Court (1) affirmed the circuit court's finding that Defendant's claim constitute an untimely petition challenging the manner in which his sentences were imposed; and (2) reversed and remanded with regard to the suspended imposition of sentences for the endangerment of a minor counts because the suspensions were imposed consecutively, one exceeded the statutory maximum for a Class D felony, and both were statutorily unauthorized and facially illegal. View "Muhammad v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's petition for relief from an illegal sentence under Ark. Code Ann. 16-90-111, holding that the circuit court did not err.Defendant pleaded guilty to first-degree murder and was sentenced as a habitual offender to fifty-three years' imprisonment. Defendant later filed a petition for relief from an illegal sentence alleging that his sentence was illegal on four grounds. The circuit court denied the petition, concluding (1) Defendant's sentence was not facially illegal in that it fell below the statutory maximum, and (2) the remaining allegations were untimely and otherwise without factual support. The Supreme Court affirmed, holding (1) Defendant sentence was within the maximum prescribed sentence and was legal on its face; and (2) Defendant's remaining allegations were unavailing. View "Smith v. State" on Justia Law

The Supreme Court accepted the findings of fact by the Arkansas Judicial Discipline and Disability Commission and its recommendation that the Court suspend the Honorable Barry Sims of the Sixth Judicial District, Seventh Division, from his duties based on certain misconduct, holding that suspension was warranted.The report of uncontested sanction arose from complaints lodged against Judge Sims concerning his courtroom comments and conduct toward members of the Bar. Judge Sims agreed that sanction of suspension was appropriate. The Supreme Court accepted the recommendation of suspension and suspended Judge Sims from his duties without pay for thirty days with an additional sixty days suspended on the condition that he performs certain remedial actions. View "Arkansas Judicial Discipline & Disability Commission v. Sims" on Justia Law

The Supreme Court reversed and dismissed the adoption order of the circuit court, holding that the circuit court erred in determining that Father's consent was not required in the adoption of his two minor children to their natural mother and her husband.Under Ark. Code Ann. 9-9-207(a)(2)(ii) consent is not required of a parent of a child in the custody of another if that period, for a period of at least one year, has failed significantly to provide for the care and support of the child as required by law or judicial decree. Mother and her husband sought to adopt the two minor children of Mother and Father, alleging that Father's consent was not required under section 9-9-207(a)(2)(ii). The circuit court granted the adoption petition. The Supreme Court reversed, holding that the circuit court clearly erred in finding that Father's consent to the adoption was not required based on the failure to provide for the care and support of the children for a period of one year. View "Plymale v. Rogers" on Justia Law