Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied the State's petition for a writ of certiorari to the circuit court's order granting a mistrial as to both the guilt and penalty phases of Defendant's capital murder trial when the event precipitating the mistrial occurred after the jury found Defendant guilty, holding that the circuit court correctly determined that the unique circumstances in this case required a mistrial as to both the guilt and penalty phases of the trial.After a retrial, a jury convicted Defendant of capital murder and first-degree battery. During the penalty phase of trial, the State's witness lunged toward Defendant in an apparent effort to assault him. After the jury left the courtroom, Defendant's counsel moved for a mistrial of the sentencing proceeding. The circuit court declared a mistrial as to both the guilt and the penalty phases of the trial. The State filed a petition for writ of certiorari seeking an order directing the circuit court to preserve the guilty verdict and conduct a new sentencing hearing only. The Supreme Court denied the petition, holding that the circuit court did not err or exceed its jurisdiction in declaring a mistrial with respect to the guilt phase of the trial. View "State v. Torres" on Justia Law

The Supreme Court affirmed Defendant's conviction for second-degree murder and sentence of life imprisonment but reversed the additional ten years added to the sentence for a firearm enhancement, holding that Defendant's ten-year sentence under Ark. Code Ann. 16-90-121 was illegal.Specifically, the Supreme Court held (1) there was sufficient evidence to support Defendant's conviction because the State met its burden of negating Defendant's justification defense; (2) the trial court did not abuse its discretion by permitting the State to introduce evidence about Defendant's gang affiliation; (3) the trial court abused its discretion in admitting certain hearsay statements attributed to the decedent as dying declarations; and (4) the trial court illegally added ten years to Gentry’s life sentence under section 16-90-121. View "Gentry v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant's claim was not cognizable in habeas proceedings.In three separate cases, Appellant was convicted of three counts of aggravated robbery, two counts of a terroristic act, rape and aggravated robbery. Appellant's current habeas petition challenged all three convictions based on defective informations. The circuit court denied habeas relief. The Supreme Court affirmed, holding that the circuit court did not clearly err when it rejected Appellant's claim for habeas relief as not cognizable. View "Benson v. Payne" on Justia Law

The Supreme Court affirmed the circuit court's order denying 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 committing a terroristic act. The Supreme Court affirmed. In his habeas petition, Appellant argued that the first-degree murder conviction and the conviction for a terroristic act constituted multiple punishments for a single action, in violation of double jeopardy protections. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant did not meet his burden of establishing that his double jeopardy claim was cognizable in a proceeding for a writ of habeas corpus. View "Starling v. Kelley" on Justia Law

The Supreme Court affirmed the circuit court's denial of Petitioner's petition to correct an illegal sentence filed pursuant to Ark. Code Ann. 16-90-111, holding that Petitioner did not allege or demonstrate in this appeal that the imposed sentences were facially illegal.Petitioner challenged the amended sentence imposed for theft of property, asserting that the property stolen did not exceed $1,000, and therefore, his sentence was excessive. The circuit court summarily denied the petition. The Supreme Court affirmed, holding that Petitioner's petition to correct the sentences imposed in the amended sentencing order was untimely and did not include a valid claim for relief under section 16-90-111. View "Green v. State" on Justia Law

The Supreme Court dismissed in part and affirmed in part the appeal of the circuit court's order granting motions to dismiss filed by hospital defendants in this medical malpractice action, holding that the circuit court did not err in dismissing Plaintiff's complaint.Plaintiff sued Catholic Health Initiatives, St. Vincent Infirmary Medical Center, and First Initiatives Insurance Company, Ltd., alleging that he fell out of his hospital bed and fractured his right hip. The circuit court granted Defendants' motion to dismiss based on Plaintiff's failure to toll the statute of limitations. The Supreme Court affirmed, holding that Plaintiff failed to comply with the notice portion of the tolling statute. View "Williams v. St. Vincent Infirmary Medical Center" on Justia Law

The Supreme Court denied Petitioner's pro se third petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's claim has been raised in previous petitions and rejected by this Court.Petitioner was convicted of residential burglary, first-degree battery, and aggravated robbery and sentenced to an aggregate term of 480 months' imprisonment. In his third coram nobis petition, Petitioner reasserted his claim that he was deprived of counsel during his criminal trial because his trial counsel's license was suspended at the time of trial. The Supreme Court denied the petition, holding that the petition was an abuse of the writ. View "Washington v. State" on Justia Law

The Supreme Court reversed the decision of the circuit court refusing to allow Cherokee Nation Businesses, LLC to intervene in litigation brought by Gulfside Casino Partnership against the Arkansas Department of Finance and Administration and the Arkansas Racing Commission, holding that Cherokee was entitled to intervention as a matter of right.Five applicants, including Gulfside and Cherokee, applied for a casino license during the May 2019 application period. The Commission denied each application on the grounds that each failed to include a letter of support from the county judge or a resolution from the county quorum court. Gulfside filed the underlying suit asking the circuit court to reverse the Commission's denial of its application. The application period was reopened in August 2019, at which time Cherokee submitted its application. Cherokee then moved for intervention to defend its right to have its application considered. The circuit court denied intervention. The Supreme Court reversed, holding that Cherokee was entitled to intervention as of right under Ark. R. Civ. P. 24(a)(2). View "Cherokee Nation Businesses, LLC v. Gulfside Casino Partnership" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder, for which he was sentenced to life imprisonment, holding that there was no prejudicial error in the proceedings below.The victim in this case died two hours after Defendant threw a cup of gasoline on him, lit a cigarette lighter, and ignited the victim's upper torso, arms, and face. On appeal, Defendant argued that there was insufficient evidence to support the first-degree murder conviction because he did not "cause" the victim's death. The Supreme Court disagreed, holding that the State presented sufficient evidence for the jury to conclude that Defendant caused the victim's death. View "Brown v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that certain rent-to-own leases were subject to the special excise tax on short-term rentals of tangible personal property levied by Ark. Code Ann. 26-63-301(b), holding that the circuit court did not err.At issue was the assessment of short-term rental tax on transactions between Appellant, Rent-A-Center East, Inc., and its customers. The Arkansas Department of Finance (DFA) and Administration issued a notice of proposed assessment to Appellant for short-term rental tax, compensating-use tax, and interest. The proposed assessment was upheld. Appellant then filed a complaint seeking judicial relief from the tax assessment, alleging that DFA wrongly classified the rental-purchase-agreement transactions as "leases" or "rentals." The circuit court granted summary judgment for DFA. The Supreme Court affirmed, holding that the transactions at issue were taxable short-term leases and not nontaxable long-term leases. View "Rent-A-Center East, Inc. v. Walther" on Justia Law