Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court dismissed the appeal in this election dispute, holding that because the election at issue had already occurred, the case was moot.In this action, Appellant, a qualified voter, challenged the ballot title of two proposed constitutional amendments referred by the General Assembly to the voters of the State of Arkansas for the November 3, 2020 general election. On October 26, 2020, the circuit court granted Appellee's motion to dismiss with prejudice. The next day, Appellant filed his notice of appeal, asserting that the circuit court erred in declining to overrule Becker v. Riviere, 641 S.W.2d 2 (Ark. 1982), and its progeny. The Supreme Court dismissed the appeal, holding that the case was moot and that none of the exceptions to mootness applied. View "Kimbrell v. Thurston" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the judgment of the circuit court finding that Democratic Party nominee Jimmie Wilson had been convicted of crimes that disqualified him under Ark. Const. art. IV, 9 from serving in the Arkansas House of Representatives and finding that Wilson's presidential pardon did not restore his eligibility to sit as a representative, holding that the circuit court did not err.In 1990, Wilson entered a guilty plea in federal court to five misdemeanor offenses. In 2001, Wilson received a presidential pardon from President William Jefferson Clinton. In 2020, Wilson was selected as the Democratic Party nominee to run in the November 3, 2020 election for the House District 12 seat. On October 15, 2020, Plaintiffs filed a complaint alleging that Wilson was disqualified from serving in the Arkansas General Assembly. The circuit court ruled that Wilson was ineligible to serve in the Arkansas House of Representatives due to his convictions and that his presidential pardon did not restore his eligibility. The Supreme Court affirmed, holding that the circuit court correctly concluded that Wilson's presidential pardon did not restore his eligibility to sit as a representative in the Arkansas General Assembly. View "Gray v. Webb" on Justia Law

Posted in: Election Law
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Here, the Supreme Court announced new protocols to maintain the safety of jurors, litigants, attorneys, court personnel and the public in light of the ongoing COVID-19 pandemic. The Court suspended until January 15, 2021 jury trials that have not begun. The Court, however, urged that judges continue to move cases forward, either through the use of technology by virtual or telephonic hearings or through in-person hearings that meet the Arkansas Department of Health's criteria for safe gatherings. The Court held that any delay for speedy-trial purposes due to precautions against the COVID-19 pandemic shall presumptively constitute good cause under Ark. R. Crim. P. 28.3(h) and shall constitute an excluded period for speedy-trial purposes. View "In Response To The COVID-19 Pandemic" on Justia Law

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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Election Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law
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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

Posted in: Criminal Law