Justia Arkansas Supreme Court Opinion Summaries

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

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

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

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

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