Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court's denial of Petitioner's pro se petition for writ of habeas corpus, holding that the chief justice had the constitutional authority to appoint a special judge, who had the jurisdiction and authority to preside over Petitioner's case.Two days before Petitioner's scheduled trial, Chief Justice Hannah appointed Honorable Ted Capeheart to preside in the place of an elected circuit court judge who had suddenly fallen ill. Twice, Petitioner filed habeas petitions alleging that Judge Capeheart lacked authority to preside over his case. The circuit court denied both petitions. The Supreme Court affirmed, holding that the Chief Justice had the constitutional authority to appoint Judge Capeheart, who consequently had the jurisdiction and authority to preside over Petitioner's case. View "Russell v. Payne" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Petitioner's claim for habeas relief but remanded the matter for resentencing, holding that Petitioner's sentence exceeded the statutory maximum for his offenses.In his pro se petition for writ of habeas corpus Petitioner alleged that his convictions for arson and first-degree battery are void because he did not plead guilty to either offense and that his sentence for first-degree murder exceeded the length provided in the sentencing guidelines. The circuit court denied the petition. The Supreme Court affirmed in part and remanded in part, holding (1) Petitioner's claims failed to demonstrate that he was illegally detained; but (2) the suspended imposition of sentences in connection with Petitioner's convictions for first-degree murder and battery exceeded the statutory maximum for the offenses, and therefore, resentencing was necessary. View "Waller v. State" on Justia Law

The Supreme Court affirmed the denial of Appellant's pro se petition for writ of habeas corpus, holding that there were no grounds stated on which a writ of habeas corpus could be issued.Defendant was convicted of two counts of negligent homicide, leaving the scene of an accident involving injury or death, driving on a suspended license, and driving while intoxicated. Defendant filed a petition for a writ of habeas corpus, raising several allegations. The Supreme Court found that Defendant's allegations did not establish probable cause for issuance of the writ. The Supreme Court affirmed, holding that Defendant was not entitled to issuance of the writ. View "Rabion v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court granting Appellees' emergency petition fro declaratory judgment and writ of mandamus declaring David Pruitt ineligible to run for public office, holding that the circuit court did not err.On February 27, 2020, Pruitt filed as a candidate for the office of alderman in the November 3, 2020 election. Appellees filed an emergency petition for declaratory judgment and writ of mandamus, alleging that Pruitt was ineligible to hold public office because he had been found guilty of voting more than once in an election in violation of Ark. Code Ann. 7-1-103(a)(19)(A), and therefore, his name may not be placed on the ballot. The circuit court granted Appellees' petition for declaratory judgment and writ of mandamus, finding that Pruitt had been convicted of certain infamous crimes in violation of Arkansas Election Law, which disqualified him from running for public office, and that Pruitt's expungement did not restore his eligibility to hold public office. The Supreme Court affirmed, holding (1) subsection (a)(19)(A) is a misdemeanor offense related to the election process and constitutes an infamous crime as contemplated by Ark. Const. art. V, 9; and (2) Pruitt's sealing of his record did not restore his eligibility to hold public office. View "Pruitt v. Smith" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, holding that the trial court did not err when it did not bring jurors into open court after they posed a question during deliberations.Defendant was convicted of capital murder and sentenced to life imprisonment without parole. For his sole point on appeal, Defendant argued that the trial court erred when it did not bring the jurors into open court after they posed a question during deliberations. The State conceded that the court violated Ark. Code Ann. 16-89-125(e) by not bringing the jury into open court when it asked a question. The Supreme Court held that because there was no risk of misinformation being communicated to the jury the State met its burden of overcoming the presumption of prejudice. View "Combs v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's pro se petition for a writ of error coram nobis, holding that the trial court did not abuse its discretion in denying relief.Defendant pleaded guilty pursuant to North Carolina v. Alford, 400 U.S. 25 (1977), to second-degree sexual assault. In his coram nobis petition, Defendant argued that his guilty plea was coerced. The trial court denied issuance of the writ. The Supreme Court denied relief, holding that the trial court did not clearly err when it gave greater weight to the testimony of Defendant's counsel and did not abuse its discretion when it denied Defendant's petition for coram nobis relief. View "Flow v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions, holding that no prejudicial error occurred during the proceedings below.Defendant was convicted of capital murder and aggravated assault. On appeal, Defendant argued that the circuit court erred in denying his motion for directed verdict and in admitting autopsy photographs after he offered to stipulate the cause of death. The Supreme Court affirmed, holding (1) substantial evidence supported Defendant's conviction; and (2) the circuit court did not abuse its discretion by admitting the autopsy photographs to aid the jury in understanding the nature and degree of the injuries the victims sustained and corroborated witness testimony. The Supreme Court remanded the case to the circuit court with directions to correct two clerical errors found in the sentencing order. View "Collins v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Plaintiff's complaint alleging that the Washington County Court order reducing the number of townships and constable positions from fifteen positions to three was illegal because constable positions may be changed only by a direct vote of the people, holding that the circuit court did not abuse its discretion.Plaintiff's argument for reversal centered on the legality of the county court order, challenging only the legality of the county court order. The Supreme Court affirmed, holding that the order was legal as a matter of law and could not support a claim for relief. View "Clowers v. Edwards" on Justia Law

The Supreme Court affirmed the order of the circuit court granting summary judgment to Professional Background Screening Association, Inc. (PBSA) on PBSA's claim pursuant to the Arkansas Freedom of Information Act (FOIA) and partial summary judgment to Jennifer Jones, the Clerk of the District Court of Benton County, Arkansas, Bentonville Division, holding that the circuit court did not err.PBSA, a nonprofit trade association, filed a complaint against Jones alleging that Jones erred in applying Arkansas Supreme Court Administrative Order Number 19 to PBSA members who request court records to perform background checks in a manner that violated their right to access court records and, instead, PBSA members' requests for court records are governed by the Arkansas Freedom of Information Act. The circuit court granted partial summary judgment in favor of PBSA on its FOIA claim and granted Jones's motion for summary judgment on PBSA's claims alleging that Order 19, as applied by Jones, violated PBSA members' right to access court records under the First Amendment and/or federal common law. The Supreme Court affirmed, holding that the circuit court did not err. View "Jones v. Professional Background Screening Ass'n" on Justia Law

In this tax refund case centering on Arkansas's excise tax on tobacco products other than cigarettes the Supreme Court affirmed the judgment of the circuit court granting summary judgment for the Director of the Arkansas Department of Finance and Administration (DF&A) and dismissing Plaintiffs' claims for refund, holding that the circuit court did not err in denying Plaintiffs' motion for summary judgment and granting DF&A's cross-motion for summary judgment.Plaintiff, seven companies that alleged that they overpaid Other Tobacco Products (OTP) taxes from 2011 through 2013, filed suit under the Arkansas Tax Procedure Act, Ark. Code Ann. 27-18-406, seeking declaratory relief in the form of a judgment that they overpaid OTP taxes. The circuit court dismissed Plaintiffs' claims for refund. The Supreme Court affirmed, holding that Plaintiffs were not entitled to a full or partial refund of the $3,223,200 they paid in excise taxes to the state during the time period in question. View "Douglas Companies, Inc. v. Walther" on Justia Law