Justia Arkansas Supreme Court Opinion Summaries

The case involves a dispute arising from a 2016 real estate transaction in which the Bauers sold residential property in Crawford County to the Beamons. The Beamons filed a complaint with two claims under the theory of fraud and deceit, seeking both monetary damages and equitable rescission of the contract. Before trial, the Beamons elected remedies associated with their equitable claim, leading to a bench trial. The circuit court rejected the rescission claim but awarded damages for breach of contract and granted the Beamons' motion for attorney’s fees.The Bauers appealed to the Arkansas Supreme Court, arguing that the circuit court erred in awarding damages for breach of contract and attorney’s fees. The Beamons cross-appealed, arguing the court erred in denying their rescission request. The Arkansas Supreme Court reversed the circuit court’s award of damages for breach of contract, affirmed the denial of rescission, and noted it lacked jurisdiction to review the attorney’s fees award due to the Bauers' failure to file an amended notice of appeal.Following the mandate, the Bauers filed motions for their own attorney’s fees and to set aside the Beamons' attorney’s-fee judgment. The circuit court concluded it lacked jurisdiction to consider these motions. The Bauers appealed this decision.The Arkansas Supreme Court reviewed the case and held that the circuit court erred in concluding it lacked jurisdiction. The court clarified that the mandate did not foreclose the circuit court from ruling on new motions for attorney’s fees, which are collateral matters, or on a motion to set aside a judgment for fraud under Arkansas Rule of Civil Procedure 60(c)(4). Consequently, the Arkansas Supreme Court reversed the circuit court’s decision and remanded the case for further proceedings on the Bauers' motions. View "BAUER v. BEAMON" on Justia Law

Eathan Cypert was convicted of first-degree murder and sentenced to life imprisonment plus 15 years for killing his wife, Kristina. The incident occurred around 2 a.m. on July 2, 2022, when Cypert shot Kristina in the back with an AR-15 following an argument. Evidence included a trail of blood, six bullet casings, and testimony from a medical examiner and on-scene investigator. Cypert was apprehended later that night, and his clothing tested positive for gunshot residue. He was charged with first-degree murder and a firearm enhancement. During the trial, the court allowed testimony about Kristina's prior bruising and Cypert's violent behavior. The jury found Cypert guilty, and he was sentenced accordingly.The Crawford County Circuit Court entered the judgment and sentence on January 29, 2024. After the verdict, a juror informed Cypert’s counsel of potential juror misconduct during deliberations. Cypert filed a motion for a new trial based on this information, which the circuit court denied on February 27, 2024. Cypert did not amend his notice of appeal to include this denial, nor did he request the voir dire or post-trial hearing transcript in the appellate record.The Supreme Court of Arkansas reviewed the case. They concluded that they lacked jurisdiction to review the denial of Cypert’s post-trial motion for a new trial based on juror misconduct because he failed to amend his notice of appeal to cover that order. Additionally, the court held that Cypert was not entitled to a second-degree murder instruction because the record did not support that instruction. The court affirmed the conviction and sentence, finding no error in the lower court's rulings. View "Cypert v. State" on Justia Law

James Woods was convicted of one count of engaging a child in sexually explicit conduct for use in visual or print medium and one count of pandering or possessing visual or print medium of a child engaging in sexually explicit conduct. Over three months, Woods raped and sexually assaulted a minor victim, filming the acts. The State charged him with multiple counts, including rape and sexual assault. A Lawrence County jury convicted him on eight counts, sentencing him to life imprisonment plus 149 years. Woods appealed, challenging the sufficiency of evidence for one pandering and one engaging conviction, both related to a two-second video of the minor victim’s bloody vagina.The Lawrence County Circuit Court granted Woods’s directed verdict for one pandering and one engaging charge but denied it for the remaining counts. The jury convicted Woods on the remaining counts. On appeal, Woods argued that there was insufficient evidence to support the two challenged convictions.The Supreme Court of Arkansas reviewed the case, noting that a motion for a directed verdict challenges the sufficiency of the evidence. The court views evidence in the light most favorable to the State and affirms if substantial evidence supports the conviction. Substantial evidence can be direct or circumstantial. The court found that the evidence, including the minor victim’s and her mother’s testimonies, Woods’s comments, and the videos found on Woods’s phone, was sufficient to support the convictions. The court concluded that the jury could reasonably determine that Woods filmed the video and that it depicted the minor victim.The Supreme Court of Arkansas affirmed Woods’s convictions, finding substantial evidence to support them. The court also reviewed the record for prejudicial errors and found none. View "Woods v. State" on Justia Law

Hunter de la Garza, a former employee of the Northwest Arkansas Children’s Shelter, was convicted of raping a ten-year-old female resident of the Shelter. The incident occurred during an outing to a mall, where de la Garza followed the victim into a restroom, forcibly undressed her, and raped her. The victim disclosed the rape to her brother and a friend, and later to a professional interviewer. The Shelter’s staff observed behavioral changes in the victim consistent with sexual abuse. De la Garza was interviewed by police and provided inconsistent accounts of the events.The Benton County Circuit Court denied de la Garza’s motion for a directed verdict, finding sufficient evidence to support the conviction. The court also allowed testimony from another young female resident of the Shelter, who described similar abuse by de la Garza, under the “pedophile exception” to Rule 404(b) of the Arkansas Rules of Evidence. The jury found de la Garza guilty and sentenced him to life in prison. De la Garza’s motion for a new trial was denied.The Arkansas Supreme Court reviewed the case and affirmed the conviction. The court held that the victim’s testimony, along with corroborating evidence, constituted substantial evidence to support the conviction. The court also found no abuse of discretion in admitting the testimony of the other young resident under the pedophile exception. Additionally, the court determined that de la Garza’s arguments regarding prosecutorial comments were not preserved for appeal, as he failed to contemporaneously object or request further relief during the trial. The court conducted a Rule 4-3(a) review and found no prejudicial error. View "HUNTER DE LA GARZA v. STATE OF ARKANSAS" on Justia Law

In December 2021, Deanna Teague and her daughter were moving into a new apartment in Lamar, Arkansas. Deanna was last seen on December 3, 2021, with Chris Oliger, who was helping her move. When Deanna failed to pick up her daughter from a sleepover, her daughter went to check on her and found the apartment trashed, with blood and a missing car. Deanna's body was discovered inside the apartment. The medical examiner confirmed that Deanna had been stabbed multiple times, with a fatal wound to the throat. DNA evidence linked Oliger to the crime scene, and social media messages revealed his plan to rob Deanna.The Johnson County Circuit Court convicted Oliger of capital murder, aggravated robbery, and theft of property. The jury found him guilty under both felony murder and premeditated murder theories. Oliger received life sentences for capital murder and aggravated robbery, and 144 months for theft of property. Oliger appealed, arguing insufficient evidence to support the verdicts.The Supreme Court of Arkansas reviewed the case. The court held that substantial evidence supported the convictions. The court noted that Oliger's social media messages before and after the murder indicated his intent to rob Deanna. Additionally, Oliger admitted to stabbing Deanna, and evidence showed he used her financial assets after her death. The court affirmed the capital murder conviction based on the felony murder theory, as the murder and robbery were part of the same transaction. The court also affirmed the aggravated robbery conviction, finding substantial evidence that Oliger intended to and did commit robbery, causing Deanna's death. The court found no prejudicial error in the record and affirmed the convictions. View "Oliger v. State" on Justia Law

In March 2017, Torry Rodgers committed aggravated robbery, theft of property by threat of serious physical injury, and felon in possession of a firearm. He entered a negotiated plea of nolo contendere in June 2018 and was sentenced to concurrent twelve-year imprisonment terms for each offense. His sentencing order noted that he would serve 100% of his sentence for aggravated robbery. Rodgers had a prior 2008 conviction for residential burglary, which was later classified as a violent felony for parole purposes under a 2015 amendment.The Pulaski County Circuit Court denied Rodgers's petition for declaratory judgment, injunctive relief, and mandamus relief, and granted the appellees' cross-motion for judgment on the pleadings. The court found that Act 683 of 2023, which amended parole eligibility calculations, did not apply to Rodgers. The court also allowed the appellees to submit Rodgers's plea agreement and a transcript of his plea hearing into the record.The Supreme Court of Arkansas reviewed the case and reversed the lower court's decision. The court held that the notation in Rodgers's sentencing order did not constitute an express designation to Arkansas Code Annotated section 16-93-609, as required by Act 683. The court found that the plain language of the statute was clear and unambiguous, and that Rodgers's prior residential burglary conviction should not be considered a violent felony for parole purposes. The court also rejected the appellees' argument for a nunc pro tunc correction of the sentencing order. The case was remanded for further proceedings consistent with the Supreme Court's interpretation of the statute. View "Rodgers v. Arkansas Parole Board" on Justia Law

Torry Rodgers entered a negotiated plea of nolo contendere in 2018 to aggravated robbery, theft of property by threat of serious physical injury, and felon in possession of a firearm, for crimes committed in 2017. He was sentenced to concurrent twelve-year terms for each offense, with a notation on his sentencing order indicating he would serve 100% of his sentence for aggravated robbery. Rodgers had a prior conviction for residential burglary in 2008, which was later classified as a violent felony for parole purposes under a 2015 amendment.The Pulaski County Circuit Court denied Rodgers's petition for declaratory judgment, injunctive relief, and mandamus relief, and granted the cross-motion for judgment on the pleadings filed by the Arkansas Parole Board and other appellees. The circuit court found that Act 683 of 2023, which amended parole eligibility calculations, did not apply to Rodgers, and that his sentencing order's notation was sufficient to designate that he was sentenced under the relevant statute.The Supreme Court of Arkansas reviewed the case and reversed the circuit court's decision. The court held that the notation in Rodgers's sentencing order did not constitute an express designation to Arkansas Code Annotated section 16-93-609, as required by Act 683. The court found that the plain language of the statute was clear and unambiguous, and that Rodgers's prior residential burglary conviction should not be considered a violent felony for parole purposes. The case was remanded for further proceedings consistent with this interpretation. View "Rodgers v. Arkansas Parole Board" on Justia Law

Perry Wright was convicted of residential burglary in 2006 and sentenced to three years' imprisonment with an additional seven years' suspended imposition of sentence. In 2020, he pleaded guilty to aggravated robbery and was sentenced as a habitual offender to twelve years' imprisonment, with a notation on his sentencing order stating "DEFENDANT IS TO SERVE FLAT TIME." In 2023, Wright filed a petition for declaratory relief, seeking to have his parole-eligibility date recalculated based on Act 683 of 2023, which he argued clarified that a pre-2015 residential-burglary conviction is not a felony involving violence for parole eligibility purposes unless explicitly stated in the sentencing order.The Pulaski County Circuit Court denied Wright's petition for declaratory judgment, injunctive relief, and writ of mandamus, as well as his motion for judgment on the pleadings. The court granted the appellees' cross-motion for summary judgment, which included Wright's institutional file and plea colloquy from his 2020 plea hearing. The court found that Act 683 did not apply to Wright and did not apply retroactively, and it considered extrinsic evidence in reaching its conclusion.The Supreme Court of Arkansas reviewed the case and found that the circuit court erred in its findings. The court held that Act 683 does apply to Wright and should be applied retroactively. Additionally, the court determined that the circuit court improperly considered extrinsic evidence. Consequently, the Supreme Court of Arkansas reversed the circuit court's order and remanded the case for further proceedings. View "Wright v. Arkansas Post-Prison Transfer Board" on Justia Law

Murphy Oil USA (Murphy) and the Arkansas Department of Finance and Administration (DFA) disputed the categorization of interest expenses related to a corporate spin-off. Murphy, a retail motor-fuel and convenience-store operator, spun off from its parent company in 2013, resulting in interest expenses from issuing senior notes and borrowing funds. Initially, Murphy apportioned these expenses among all states where it conducted business. In 2018, Murphy amended its Arkansas tax returns for 2014 and 2015 to allocate all interest expenses to Arkansas, seeking a tax refund of nearly $4 million.The Union County Circuit Court granted summary judgment in favor of Murphy, allowing the amended tax returns and the allocation of 100% of the interest expenses to Arkansas. DFA appealed, arguing that the interest expenses were business-income expenses under the Uniform Division of Income for Tax Purposes Act (UDITPA) and should be apportioned among all states, that a state statute made the expenses non-deductible if allocable to Arkansas, and that it was unfair to allow Murphy a tax refund in Arkansas without amending returns in other states.The Supreme Court of Arkansas affirmed the circuit court's decision. The court held that Murphy's spin-off was an extraordinary, nonrecurring event, classifying the interest expenses as nonbusiness income under UDITPA, thus allocable entirely to Arkansas. The court also found that Arkansas Code Annotated section 26-51-431(c) did not prohibit the deduction of these expenses, as the statute was intended to prevent deductions for expenses related to tax-exempt income, which was not applicable in this case. Finally, the court rejected DFA's fairness argument, stating that it was not the court's role to adjust Arkansas tax returns based on potential unfairness to other states. View "Hudson v. Murphy Oil USA, Inc." on Justia Law

In 1995, Grady McGowan was convicted of residential burglary. In 2020, he pleaded guilty to residential burglary again and was sentenced to nine years in prison with an additional eleven-year suspended sentence. His sentencing order noted that he might be ineligible for parole due to a prior felony conviction. The Arkansas Division of Correction initially determined McGowan was eligible for parole and provided him a parole hearing, but later rescinded this decision based on a 2022 opinion from the Arkansas Attorney General, which led to a recalculation of his parole-eligibility date.McGowan filed a petition in the Pulaski County Circuit Court seeking declaratory judgment on his parole eligibility under Act 683 of 2023. The circuit court granted declaratory relief in favor of McGowan, finding that the sentencing order did not expressly designate his ineligibility for parole as required by the statute. The court ordered the appellants to modify his parole-eligibility date but denied further relief, stating that McGowan's release was an issue for the Arkansas Post-Prison Transfer Board.The Arkansas Supreme Court reviewed the case and affirmed the circuit court's decision. The court held that McGowan's sentencing order did not contain the express designation required by Arkansas Code Annotated section 16-93-609(b)(2)(B) to render him ineligible for parole. The court also declined to remand the case for the sentencing order to be amended nunc pro tunc. The decision was consistent with the court's reasoning in a companion case, Rodgers v. Arkansas Parole Board. View "Post-Prison Transfer Board v. McGowan" on Justia Law