Justia Arkansas Supreme Court Opinion Summaries

The case involves Little Scholars of Arkansas, AP Consolidated Theatres II L.P., CSRC Charter LISA, LLC, and KLS Leasing LLC (collectively, appellants) who appealed against Pulaski County, Arkansas, and its officials (collectively, appellees). The appellants operate charter schools and lease properties for their schools. The appellees assessed real-property taxes against the schools, which the appellants contested, arguing that the properties used for school purposes are exempt from taxes under the Arkansas Constitution. The appellants also sought a declaration that Ark. Code Ann. § 6-21-118, which they claimed the appellees relied on for the tax assessment, is void under the constitution.The case was initially brought before the Pulaski County Circuit Court. The appellees moved to dismiss the case, arguing that the county courts have exclusive jurisdiction over county tax matters. The circuit court agreed with the appellees, dismissing the case on the grounds that it lacked subject-matter jurisdiction over the appellants' claims.The case was then brought before the Supreme Court of Arkansas. The appellants argued that the circuit court did have subject-matter jurisdiction over their illegal-exaction claims. They also argued that their request for a declaration that Ark. Code Ann. § 6-21-118 is void does not fall within the county court’s jurisdiction. The Supreme Court disagreed with the appellants, affirming the circuit court's decision. The Supreme Court held that the appellants' claim was not an illegal-exaction claim but an assessment dispute, which falls within the exclusive original jurisdiction of the county court. The Supreme Court also held that the circuit court did not have subject-matter jurisdiction over the appellants' request for declaratory judgment. View "LITTLE SCHOLARS OF ARKANSAS FOUNDATION v. PULASKI COUNTY, ARKANSAS" on Justia Law

The case revolves around a dispute between the City of Helena-West Helena and its Mayor, Christopher Franklin, and a resident, Greg Williams. The dispute arose when the Helena-West Helena City Council passed two ordinances, one increasing the conflict-of-interest limit for contracts signed with the City and the other raising the mayor's base pay. The then-mayor, Kevin Smith, vetoed both ordinances, citing the timing of the meeting as an attempt to circumvent the new city council. When Mayor Franklin took office, he attempted to rescind Smith's veto, stating that the ordinances should become law.The Phillips County Circuit Court had previously granted Williams's request for declaratory relief, ruling that the previous mayor's veto of the two city ordinances was proper. The court found that Smith had timely and properly executed a veto regarding the ordinances and that his veto was not overridden by a two-thirds vote of the City Council. As a result, the court declared all actions taken by the Council on December 30, including the passage of the two ordinances, null and void.The Supreme Court of Arkansas affirmed the lower court's decision. The court disagreed with the appellants' argument that Smith's veto was ineffective due to his failure to comply with the statutory requirements. The court found that Smith had complied with the statute by timely vetoing the Council's actions and filing a written statement of his reasons for the veto prior to the next regular Council meeting. The court also disagreed with the appellants' interpretation of the statute, stating that the statute does not affirmatively require that the mayor's reasons for the veto be presented to the Council in order to effectuate the veto. View "CITY OF HELENA-WEST HELENA v. WILLIAMS" on Justia Law

The case revolves around Corey Jeffery, who was convicted of capital murder and first-degree unlawful discharge of a firearm from a vehicle by the Arkansas County Circuit Court. The victim, Christopher Haynes, was found dead in his car at his workplace, Riceland Foods plant. The investigation led to the identification of a Dodge Ram truck, distinctive in its features, which was likely involved in the homicide. Jeffery and Jonathan Dabner were identified as suspects, with Dabner pleading guilty in a separate case to unlawful discharge of a firearm from a vehicle. Evidence against Jeffery included a .40-caliber Smith & Wesson bullet found in the truck, a receipt for the purchase of a .40-caliber handgun and ammunition, and video footage of Jeffery and Dabner at the gun store. Jeffery's wife testified about an alleged affair between her and the victim, which had caused friction in their marriage.The trial court denied Jeffery's motions for directed verdict, and the jury convicted him of capital murder and first-degree unlawful discharge of a firearm from a vehicle. He was sentenced to life imprisonment plus seventy years with an enhancement of fifteen years on each count for committing a felony with a firearm. Jeffery appealed, arguing that the circuit court erred in denying his motions for directed verdict, claiming that the State failed to present substantial evidence that he committed the offenses.The Supreme Court of Arkansas affirmed the lower court's decision. The court found substantial evidence supporting the convictions, including Jeffery's access to a .40-caliber handgun, his presence at the crime scene, and his attempt to silence a witness. The court concluded that the jury could have reached a conclusion with reasonable certainty, without resorting to speculation or conjecture, that Jeffery discharged a firearm from a vehicle, causing Haynes's death under circumstances manifesting extreme indifference to the value of human life. View "Jeffery v. State" on Justia Law

The case involves Conrad Reynolds, Arkansas Voter Integrity Initiative, Inc., and Restore Election Integrity Arkansas (collectively referred to as the petitioners) who filed an original action against John Thurston, in his official capacity as Secretary of State, and the State Board of Election Commissioners (collectively referred to as the respondents). The petitioners submitted two proposed measures to amend the Arkansas Constitution to the Attorney General for approval. One measure would have required elections to be conducted with paper ballots, and the other would have changed absentee-voting procedures. The Attorney General rejected both measures, citing various reasons such as conflicting provisions, unclear language, and redundancy. The petitioners resubmitted the measures to the Attorney General, the Secretary of State, and the State Board of Election Commissioners for certification, but the Secretary and the Board refused to examine the sufficiency of the ballot titles and popular names.The petitioners then filed this original-action complaint, asking the court to independently certify the legal sufficiency of the measures’ ballot titles and popular names and order them placed on the November 2024 ballot. They also asked the court to declare Arkansas Code Annotated section 7-9-107 and section 7-9-126(e) unconstitutional, arguing that these sections violate Article 5, section 1 of the Arkansas Constitution.The Supreme Court of Arkansas dismissed the complaint, ruling that it only has original jurisdiction over the sufficiency of petitions after the Secretary of State has made a sufficiency determination. The court found that the petitioners' request for a declaration that the statutes are unconstitutional falls outside its original jurisdiction. The court also noted that the petitioners could have filed a declaratory-judgment action in the circuit court to determine the constitutionality of the statutes. View "Reynolds v. Thurston" on Justia Law

The Supreme Court of Arkansas reviewed four acts passed by the Arkansas General Assembly that were challenged by the League of Women Voters of Arkansas and other appellees. The acts in question were Acts 736, 973, 249, and 728 of 2021, which pertained to various aspects of the election process, including the verification of voter signatures on absentee ballots, the deadline for in-person delivery of absentee ballots, the requirement for voters to present valid photographic identification, and the prohibition of certain activities within 100 feet of a voting location. The circuit court had previously ruled these acts unconstitutional and permanently enjoined their enforcement.The circuit court's decision was based on the argument that the acts violated various provisions of the Arkansas Constitution and would burden lawful, eligible voters in the exercise of their right to vote. The appellants, including John Thurston in his official capacity as Secretary of State for the State of Arkansas and members of the Arkansas State Board of Election Commissioners, appealed this decision.The Supreme Court of Arkansas reversed the circuit court's decision, holding that the acts were not clearly incompatible with the sections of the Arkansas Constitution as alleged by the appellees. The court found that the acts were neutral on their face and did not contain any discriminatory classifications. The court also found that the acts did not add voter qualifications beyond those contained in the constitution, nor did they violate the free and equal election clause of the Arkansas Constitution. The court concluded that the circuit court erred in its application of strict scrutiny to the acts and in its finding that the acts violated various constitutional provisions. The court's decision resulted in the reversal and dismissal of the circuit court's ruling. View "THURSTON V. THE LEAGUE OF WOMEN VOTERS OF ARKANSAS" on Justia Law

The case revolves around Raymond Bailey, a probationer who signed a waiver allowing law enforcement to conduct warrantless searches of his person, residence, and vehicle. In June 2020, North Little Rock Police observed Bailey engaging in suspicious activities indicative of illegal drug transactions. They discovered that Bailey was on probation and had signed a search waiver. Upon detaining Bailey, they found a key to a motel room, which they subsequently searched, finding heroin and drug paraphernalia. Bailey was charged, but he moved to suppress the evidence, arguing that the police did not have probable cause to believe that the motel room was his residence.The Pulaski County Circuit Court granted Bailey's motion to suppress, ruling that law enforcement must have probable cause to believe that the place to be searched is the probationer's residence. The court found that the police did not have probable cause to believe that the motel room was Bailey's residence, and therefore, the warrantless search violated the Fourth Amendment. The State of Arkansas appealed this decision.The Supreme Court of Arkansas disagreed with the lower court's ruling. The Supreme Court held that the correct legal standard requires law enforcement to have a reasonable suspicion, based on the totality of the circumstances, to believe the place to be searched is the probationer's residence if conducting a search under that provision. The court found that the police had a reasonable suspicion that Bailey was residing in the motel room, making the search permissible under the statute and consistent with the Fourth Amendment. Therefore, the Supreme Court reversed the decision to suppress the evidence and remanded the case back to the circuit court. View "STATE OF ARKANSAS v. BAILEY" on Justia Law

The Supreme Court of Arkansas reviewed a case involving four acts passed by the Arkansas General Assembly concerning the election process. The League of Women Voters of Arkansas and other appellees challenged the constitutionality of these acts, which were subsequently deemed unconstitutional by the circuit court and permanently enjoined. The appellants, including John Thurston in his official capacity as Secretary of State for the State of Arkansas and members of the Arkansas State Board of Election Commissioners, appealed this decision.The circuit court had ruled that the acts violated various provisions of the Arkansas Constitution and would burden lawful, eligible voters in the exercise of their right to vote. The appellants argued that the acts were enacted to protect the integrity of Arkansas elections by preventing fraudulent voting and to promote public confidence in election security. The circuit court applied strict scrutiny to the acts, finding that they failed to advance a compelling government interest or were not the least-restrictive infringement on the rights guaranteed by the Arkansas Constitution.The Supreme Court of Arkansas reversed the circuit court's decision, holding that the acts were not clearly incompatible with the sections of the Arkansas Constitution as alleged by the appellees. The court found that the acts were neutral on their face and did not contain any discriminatory classes, thus not invoking equal protection. The court also found that the acts did not violate the free and equal election clause, the voter qualifications clause, or the free speech and free assembly clauses of the Arkansas Constitution. The court concluded that the circuit court had erred in its application of strict scrutiny and in its findings that the acts violated these constitutional provisions. The case was dismissed. View "THURSTON V. THE LEAGUE OF WOMEN VOTERS OF ARKANSAS" on Justia Law

A group of online travel companies (OTCs), including Hotels.com, Expedia, and Priceline, were found liable by the Jefferson County Circuit Court for unpaid taxes under several Arkansas tax statutes. The court ordered the OTCs to pay the unpaid taxes, along with penalties, interest, and attorney's fees. The OTCs appealed, arguing that the court erred in imposing the taxes and awarding penalties.The case began in 2009 when the Pine Bluff Advertising and Promotion Commission and Jefferson County, Arkansas, filed a declaratory-judgment action against the OTCs, seeking a declaration that the OTCs were liable for local gross receipts tax and local tourism tax. The City of North Little Rock intervened in the case in 2011, alleging a similar claim. The circuit court granted class certification in 2013. In 2018, the circuit court denied the OTCs' motion for summary judgment and granted the class appellees' motion, finding that the OTCs were liable for the taxes.The Supreme Court of Arkansas reversed the lower court's decision. The court found that the OTCs were not entities subject to the pre-2019 versions of the state and local gross receipts tax and the state tourism tax. The court also found that the OTCs did not rent, lease, or furnish rooms under the plain meaning of the local tourism tax statute. Therefore, the court held that the OTCs were not liable for the pre-2019 hotel taxes. The court did not address the OTCs' remaining arguments for reversal. View "HOTELS.COM, L.P. V. PINE BLUFF ADVERTISING AND PROMOTION COMMISSION" on Justia Law

The case revolves around Maurice Richardson, who was convicted of second-degree murder, rape, and abuse of a corpse. The victim, Tonia Tran, was found suffocated to death, severely beaten, and with vaginal injuries. Evidence linked Richardson to the crime, including Tran's blood found in his bedroom and her car, her body wrapped in a bedspread matching pillow shams from his home, and a cigarette butt with his DNA near her body. Richardson had initially denied his relationship with Tran but later admitted to living with her and having sex recently. However, he denied involvement in the murder.Richardson was initially charged with first-degree murder, rape, and abuse of a corpse. He moved for a directed verdict on all charges, arguing insufficient evidence to prove he caused Tran's death, that Tran was alive during the sexual activity, or that it was done for sexual gratification. He also argued that there was no evidence he knowingly mistreated or concealed a corpse in an offensive manner. The circuit court denied the motions, and the jury convicted him of second-degree murder, rape, and abuse of a corpse. He was sentenced as a habitual offender to sixty years’ imprisonment, life imprisonment, and thirty years’ imprisonment, respectively.In the Supreme Court of Arkansas, Richardson argued that insufficient evidence supported his murder and rape convictions. The court, viewing the evidence in the light most favorable to the verdict, found substantial evidence to support the convictions. The court noted that Richardson's DNA was found near Tran's body, her blood was found in his bedroom and her car, and her body was wrapped in bedding matching items from his home. The court also noted Richardson's attempts to conceal the crime, including moving a blood-stained mattress and Tran's belongings, buying new bedding, and lying about his relationship with Tran. The court affirmed the lower court's decision. View "Richardson v. State" on Justia Law

The case revolves around the appellant, Jacovan Bush, who was convicted of capital murder, aggravated residential burglary, aggravated robbery, and theft of property. The charges stemmed from an incident where men broke into Devon Howard's apartment and killed him. Bush was arrested after his blood was found at the crime scene and matched the DNA samples. Bush's defense argued that the blood stains were dry when found, suggesting they were shed before the murder. However, a crime-scene specialist testified that a specific blood sample was fresh when she arrived but had dried by the time law enforcement finished clearing the scene.Prior to the trial, Bush had moved to exclude the crime-scene specialist's testimony, arguing it was improper expert testimony. The circuit court denied this motion. During the trial, the State presented several witnesses, including the crime-scene specialist, who testified about the blood evidence. After the State rested, Bush moved for a directed verdict on all counts, which the circuit court denied. The jury found Bush guilty on all counts, and he was sentenced to life imprisonment without parole, plus an additional forty years.On appeal, Bush argued that the circuit court erred in denying his motion for a directed verdict due to insufficient evidence and in denying his motion to exclude the crime-scene specialist's testimony. The Supreme Court of Arkansas affirmed the lower court's decision, holding that there was substantial evidence to support the convictions and that the circuit court did not abuse its discretion in admitting the crime-scene specialist's testimony. The court noted that the jury could have reasonably concluded that Bush was in the apartment around the time of the murder based on the DNA evidence and the testimony about the blood's condition. View "BUSH v. STATE OF ARKANSAS" on Justia Law