Justia Arkansas Supreme Court Opinion Summaries
Commons v. Kelley
The Supreme Court affirmed the order of the circuit court denying Appellant's petition to proceed in forma paupers in connection with a petition for a writ of habeas corpus, holding that the circuit court correctly determined that Appellant failed to state a colorable cause of action.Appellant was convicted of three counts of unlawful discharge of a vehicle and was sentenced as a habitual offender to seventy-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus seeking relief based on insufficient evidence supporting a firearm enhancement and an alleged double jeopardy violation. The circuit court denied the petition. The Supreme Court affirmed, holding that the petition clearly failed to allege a colorable cause of action. View "Commons v. Kelley" on Justia Law
Posted in:
Criminal Law
Flow v. State
The Supreme Court affirmed the order 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 did not err in denying the petition.Appellant pled guilty to two counts of second-degree sexual assault and sentenced to 300 months' imprisonment. Appellant filed a motion to correct an illegal sentence, arguing that the sentencing order was illegal on its face because the prosecutor made a notation that Appellant was not eligible for parole pursuant to Ark. Code Ann. 16-93-609. The circuit court denied the motion. The Supreme Court affirmed, holding that section 16-93-609 applied to Appellant's conviction and that Appellant failed to demonstrate that his sentence were illegal. View "Flow v. State" on Justia Law
Posted in:
Criminal Law
Anderson v. Payne
The Supreme Court affirmed the circuit court's denial of Appellant's petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition and in finding of an abuse of the writ.Appellant filed multiple postconviction actions challenging his sentence. Less than thirty days after the Supreme Court affirmed the order of the circuit court denying Appellant's second pro se petition for writ of habeas corpus Appellant filed the instant pro se petition for writ of habeas corpus. The circuit court dismissed the petition and found an abuse of the writ. The Supreme Court affirmed, holding that the circuit court did not clearly err when it denied and dismissed Appellant's habeas petition. View "Anderson v. Payne" on Justia Law
Posted in:
Criminal Law
Hill v. State
The Supreme Court affirmed the circuit court's dismissal of Appellant's petition for ineffective assistance of counsel filed under Ark. R. Crim. P. 37, holding that Appellant was not entitled to relief.Appellant was convicted of aggravated residential burglary and sentenced to life in prison. In his Rule 37 postconviction petition, Appellant claimed that his trial counsel was ineffective on ten grounds. The circuit court denied the petition after holding a hearing. The Supreme Court affirmed, holding that Appellant was provided constitutionally effective assistance of counsel, and therefore, his petition for postconviction relief failed. View "Hill v. State" on Justia Law
Posted in:
Criminal Law
Collins v. State
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
Jones v. Payne
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
C.J. Mahan Construction Co. v. Betzner
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
Jones v. State
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
Arkansas Ethics Commission v. Weaver
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
Posted in:
Election Law, Government & Administrative Law
Dirickson v. State
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