Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the order of the circuit court convicting Appellant of first-degree murder, attempted first-degree murder, aggravated assault, and committing first-degree murder in the presence of a child, holding that substantial evidence supported the convictions.On appeal, Defendant challenged the sufficiency of the evidence supporting his first-degree murder and attempted first-degree murder convictions. The Supreme Court affirmed, holding (1) the State presented substantial evidence of the requisite mental state for first-degree murder; (2) substantial evidence supported Defendant's conviction for attempted first-degree murder; and (3) after examining the record, no prejudicial error has been found. View "Collins v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus filed pursuant Ark. Code Ann. 16-112-101 to -123, holding that the circuit court did not err.Appellant was convicted of four counts of rape and sentenced to 480 months' imprisonment. Appellant later filed the pro se petition for writ of habeas corpus that was the subject of this appeal, making several claims. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate probable cause for the writ to issue. View "Jones v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order the circuit court certifying a class action against Defendants, holding that the circuit court did not err or abuse its discretion.Plaintiffs filed a class action complaint against Defendants, alleging, on their own behalf and on behalf of others similarly situated, that their water systems were contaminated with sewage due to Defendants' negligence. Plaintiffs moved for class certification. The circuit court certified the class as to their negligence and breach of contract claims. On appeal, Defendants argued that the circuit court erred in finding that class was ascertainable and that common issues predominated and erred in certifying the breach of contract claim. The Supreme Court affirmed, holding that the circuit court did not err in certifying the class. View "C.J. Mahan Construction Co. v. Betzner" on Justia Law

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The Supreme Court reversed the order of the circuit court declaring Bobby Lee Jones ineligible to hold the office of Justice of the Peace, holding that the trial court erred by not providing Jones with a hearing on the propriety of taking judicial notice of an order in a prior case.In 2006, Jones ran for Justice of the Peace for Phillips County, District One. The court entered an order (2006 order) concluding that Jones was a convicted felon and was therefore ineligible to hold public office. In 2020, Jones again ran for Justice of the Peace for Phillips County, District One. In response, the State brought suit seeking a declaratory judgment that Jones was ineligible to hold office because of his prior felony convictions. During trial, the trial court took judicial notice of the 2006 order, determined that res judicata applied, and concluded that Jones was ineligible to hold public office. The Supreme Court reversed, holding that the trial court erred by not providing Jones with a hearing on the propriety of taking judicial notice of the 2006 order. View "Jones v. State" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the decision of the circuit court vacating the finding of the Arkansas Ethics Commission that Susan Weaver violated Ark. Code Ann. 7-6-228(c)(1) when a magazine published her campaign advertisement without a required disclosure during Weaver's 2018 judicial campaign, holding that substantial evidence did not support the Commission's decision.Faulkner Lifestyle published an ad of Weaver's candidacy without statutorily required financial disclosure language. The Commission found that section 7-6-228(c)(1) did not require a culpable mental state but, if it did, Weaver violated the statute by acting negligently. The circuit court vacated the finding, holding that the Commission erred in concluding that the standard of proof for a violation of section 7-6-228(c)(1) is strict liability and that insufficient evidence supported the Commission's finding that Weaver was negligent. The Supreme Court affirmed, holding that substantial evidence did not support the Commission's conclusion. View "Arkansas Ethics Commission v. Weaver" on Justia Law

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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 the circuit court correctly denied the petition as timely.Appellant was convicted of three counts of capital murder, one count of attempted rape, and one count of residential burglary. The circuit court sentenced Appellant to 140 years' imprisonment. Appellant later filed a petition to correct an illegal sentence, which was denied. The Supreme Court affirmed, holding that the circuit court did not clearly err by denying Appellant's petition as untimely under Ark. R. Crim. P. 37.2(c). View "Dirickson v. State" on Justia Law

Posted in: Criminal Law
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In this case stemming from a motor vehicle accident the Supreme Court affirmed as modified the circuit court's order dismissing with prejudice Plaintiffs' claims against against Defendant, holding that the circuit court correctly dismissed the claims but directed that the dismissal be without prejudice.In his motion to dismiss, Defendant alleged that he had not been properly or timely served and requested that the complaint be dismissed pursuant to Ark. R. Civ. P. 4(i) and 12(b)(5). The circuit court found that the motion should be granted and dismissed the complaint with prejudice. The Supreme Court affirmed as modified, holding (1) the circuit court did not err by concluding that service of the summons and complaint on Defendant was insufficient; but (2) because Plaintiffs' timely attempted service commenced the suit for purpose of the savings statute, the statute of limitations was tolled and provided Plaintiffs one year to refile their suit. View "White v. Owen" on Justia Law

Posted in: Personal Injury
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The Supreme Court granted a petition for a writ of prohibition filed by Petitioners - Respondent's employer, its corporate parent, and a fellow employee - asking the court to dismiss Respondent's declaratory judgment action because declaratory judgment would be improper on the facts, holding that the circuit court lacked jurisdiction to hear this petition.Respondent was injured in a workplace accident and received workers' compensation benefits because of his injuries. Respondent brought this declaratory judgment action, arguing that the petition was necessary to establish the legal relations between the parties. Petitioners filed this petition for writ of prohibition arguing that the Workers' Compensation Commission held exclusive jurisdiction for any claims Respondent had against his employers. The Supreme Court granted the writ, holding that Respondent's remedies against his employer were those outlined under the Workers' Compensation Act. View "Esterline Technologies Corp. v. Brownlee" on Justia Law

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The Supreme Court affirmed Defendant's conviction of rape, second-degree sexual assault, and third-degree domestic battery, holding that the circuit court did not err or abuse its discretion.On appeal, Defendant argued that the circuit court erred by admitting as hearsay a journal entry, list, and letter written by the victim and abused its discretion by admitting evidence of his suicide attempt during his arrest. The Supreme Court affirmed, holding (1) any error resulting the admission of the victim's writings was harmless; and (2) the circuit court did not abuse its discretion in admitting evidence of suicide threats made during Defendant's arrest. View "Adams v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court dismissed this appeal from the denial of Appellant's pro se motion to enforce his plea agreement, holding that Appellant's motion to enforce the plea agreement represented an untimely postconviction motion, and therefore, Appellant's notice of appeal was untimely.Appellant pled guilty to two counts of first-degree murder and was sentenced to forty-five years' imprisonment. In his motion to enforce the plea agreement, Appellant argued that the sentence he received was not the sentence included in the plea agreement. The circuit court denied the motion. The Supreme Court dismissed Appellant's appeal, holding that both Appellant's motion to enforce the plea agreement and his notice of appeal were untimely, and therefore, neither the circuit court nor the Supreme Court had authority to grant the relief sought. View "Manuel v. State" on Justia Law

Posted in: Criminal Law