Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court reversed the order of the circuit court dismissing Plaintiffs' illegal exaction suit that sought to enjoin the expenditure of highway funds collected pursuant to Amendment 91 of the Arkansas Constitution for two highway projects, holding that the circuit court erred in finding that Amendment 91 funds were legally designated for the projects.The two projects at issue were intended to improve portions of Interstate 30 and Interstate 630 in Little Rock by widening portions of the interstate highways from six lanes to eight or more lanes. The Arkansas Department of Transportation selected the projects to be funded by Amendment 91 money. Plaintiffs, Arkansas citizens and taxpayers, filed an illegal exaction lawsuit praying to enjoin the expenditure of funds for the projects, arguing that the projects were not "four-lane highway improvements," as required by Amendment 91. The circuit court found that the projects were covered by Amendment 91. The Supreme Court reversed, holding (1) the repeated reference to "four-lane highways" and the lack of a specific reference to six-lane interstate highways means the Amendment 91 funds cannot be used for six-lane interstate highways; and (2) therefore, the circuit court erred in dismissing the illegal exaction suit. View "Buonauito v. Gibson" on Justia 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, holding that Appellant failed to state a basis for issuance of the writ.Appellant was convicted of four counts of computer exploitation of a child in the first degree and twenty counts of distributing, possessing, or viewing matter depicting sexually explicit conduct involving a child. Appellant later filed a petition for a writ of corpus alleging that his convictions were invalid for several reasons. The circuit court denied and dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish that the circuit court erred by denying habeas relief. View "Rea v. Kelley" on Justia Law

Posted in: Criminal Law
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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 none of Appellant's allegations were cognizable in a habeas proceeding.Appellant entered a guilty plea to three counts of first-degree terroristic threatening and was sentenced to 120 months in prison. In his habeas petition, Appellant argued that there was insufficient evidence to support the convictions, his arrest was illegal, and his guilty plea was rendered involuntary by flaws in the plea proceedings. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's habeas claim was properly denied. View "Lewis v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court granting class certification of Plaintiffs' complaint, holding that the circuit court did not abuse its discretion in certifying the class.Plaintiffs were hourly employees of Koppers, Inc. Plaintiffs filed this action against Koppers alleging that Koppers did not pay them for working overtime in violation of the Arkansas Minimum Wage Act (AMWA), Ark. Code Ann. 11-4-211(a). Plaintiffs filed a motion to certify a class. The circuit court granted the motion. Koppers appealed, arguing that its liability could not be established on a classwide basis because whether a plaintiff could recover depended on individualized facts. The Supreme Court affirmed, holding that the circuit court's findings on commonality, predominance, and superiority were not in error. View "Koppers, Inc. v. Trotter" on Justia Law

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The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for a writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in declining to grant the relief sought.In two separate criminal cases, Appellant pled guilty to multiple charges of commercial burglary. In his coram nobis petition, Appellant argued that his guilty plea was coerced when two police officers threatened to charge his wife. The trial court denied the petition. The Supreme Court affirmed, holding that Appellant's claim of coercion was unsubstantiated and that, even if it were substantiated, Appellant failed to pursue the claim with diligence. View "Lewis v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus filed in the county where Appellant was incarcerated pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue.Appellant was convicted of aggravated robbery, first-degree battery, and attempted rape and was sentenced as a habitual offender. In his habeas corpus petition, Appellant asserted that he was deprived of his right to an appeal due to his counsel's procedural error, that his conviction for attempted rape was not supported by sufficient evidence, and that his parole eligibility date was miscalculated. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. View "Hall v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court granting summary judgment in favor of the director of the Arkansas Department of Finance and Administration (DFA) and dismissing American Honda Motor Company's challenge to the DFA's denial of its request for a corporate tax refund, holding that the circuit court correctly granted summary judgment in favor of DFA.American Honda filed an action for judicial relief under the Arkansas Tax Procedure Act, Ark. Code Ann. 26-18-101 et seq., challenging DFA's decision to deny its request for a corporate tax refund. The circuit court granted summary judgment in favor of DFA. The Supreme Court affirmed, holding (1) judicial review of DFA's statutory interpretation of the Tax Procedure Act is de novo; and (2) while the circuit court improperly gave great deference to DFA's interpretation of the Tax Procedure Act, the circuit court correctly granted summary judgment in favor of DFA. View "American Honda Motor Co. v. Walther" on Justia Law

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The Supreme Court affirmed the trial court's denial of Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying relief.Appellant was convicted of capital murder and sentenced to life imprisonment without parole. In this habeas petition, Appellant alleged that the arrest warrant was invalid, the trial court lacked the authority to amend the information, and the sentencing order was void. The circuit court dismissed the habeas corpus petition on the merits. The Supreme Court affirmed, holding (1) because Appellant's first two claims had been raised and rejected before and Appellant failed to bring new facts to enliven the claims, that failure constituted an abuse of the writ; and (2) the arguments Appellant made in support of his third argument lacked merit. View "Watson v. Payne" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree murder and possession of a firearm by certain persons and sentencing him to life imprisonment, holding that the circuit court did not err in finding that Appellant was fit to proceed to trial.After he was charged with first-degree murder and possession of a firearm Defendant moved for a competency determination. The circuit court found Defendant was not fit to proceed and committed him to the custody of the Arkansas State Hospital until he was restored to fitness. After Defendant underwent restoration proceedings the circuit court again held a hearing and found that Defendant was fit to proceed to trial. A jury subsequently found Defendant guilty. The Supreme Court affirmed, holding that the circuit court did not err in determining that Defendant was fit to stand trial. View "Hampton v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that Appellant's claim was not cognizable in a writ of habeas corpus.Appellant pleaded nolo contendere to multiple felony counts in three separate criminal cases. Appellant later filed a pro se petition for habeas corpus alleging that the sentences in these cases were illegal because the circuit court imposed a habitual-offender enhancement without proof that Appellant had committed more than one but less that four prior felonies. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was not within the purview of the habeas corpus remedy. View "Trammel v. Kelley" on Justia Law

Posted in: Criminal Law