Justia Arkansas Supreme Court Opinion Summaries
Caple v. State
The Supreme Court affirmed Appellant's conviction of rape and second-degree sexual assault and sentence of life imprisonment and twenty years' imprisonment, respectively, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) substantial evidence supported the jury's conclusion that Appellant committed rape; (2) the circuit court did not abuse its discretion by not instructing the jury on the offense of attempted rape; and (3) the circuit court did not abuse its discretion by allowing a witness to testify at sentencing about child-abuse statistics. View "Caple v. State" on Justia Law
Posted in:
Criminal Law
Jones v. State
The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that none of Petitioner's claims established a ground for the writ.In his petition, Petitioner asserted that the prosecution withheld material evidence in violation of Brady v. Maryland, 373 U.S. 83 (1963), and withheld facts regarding information obtained during the police investigation. Petitioner later filed a motion asserting additional bases for issuance of the writ. The Supreme Court denied the petition and the motion, holding that Petitioner did not state sufficient allegations to satisfy issuance of the writ. View "Jones v. State" on Justia Law
Posted in:
Criminal Law
Robinson v. State
The Supreme Court affirmed the decision of the trial court denying Defendant's pro se motion for an independent action to set aside his conviction for fraud, holding that the trial court did not err in denying the motion on the basis that Defendant was precluded from seeking postconviction relief under Ark. R. Civ. P. 60(k).Defendant pleaded guilty to first-degree murder and was sentenced to life imprisonment. Defendant later filed a Rule 60(k) motion for an independent action to set aside his judgment for fraud upon the court, alleging that he did not agree to plead guilty in exchange for a life sentence. The circuit court denied the petition. The Supreme Court affirmed, holding that Rule 60 does not apply to criminal proceedings such as this one. View "Robinson v. State" on Justia Law
Posted in:
Criminal Law
Dominique v. State
The Supreme Court granted Petitioner's pro se motion for rule on clerk and denied Petitioner's pro se motion for transcript, petition for writ of mandamus, and motion for appointment of counsel, holding that Petitioner was entitled to relief pursuant to Rule 2-2 of the rules of the Supreme Court.Petitioner was convicted of rape, aggravated residential burglary, and other crimes. In his motion for rule on clerk, Petitioner alleged that his counsel failed to perfect an appeal from his convictions by neglecting to lodge the record. The Supreme Court agreed, holding (1) because there was no order dismissing the appeal or otherwise relieving counsel from their obligation to perfect the appeal, counsel for Petitioner were obligated to lodge the record in the appellate court and to continue representing Petitioner; (2) because Petitioner's remedy lay in his motion for rule in clerk, his writ of mandamus is denied; and (3) Petitioner's motions either did not comply with the criminal rules of appellate procedure or were premature. View "Dominique v. State" on Justia Law
Posted in:
Criminal Law
Steele v. Thurston
The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by the Arkansas Secretary of State Appellant's complaint seeking to strike two proposed constitutional amendments, Issue 2 and Issue 3, from the general election ballot on November 3, 2020, holding that the circuit court did not err.On appeal, Appellant argued that the circuit court erred in ruling that the ballot titles were sufficient and that Issue 3 did not violate Ark. Const. art. XIX, 22. The Supreme Court affirmed, holding (1) article 19, section 22 governs the ballot titles of Issue 2 and Issue 3; (2) the circuit court properly ruled that Issue 2 and Issue 3 comply with the requirements of article 19, section 22; and (3) the circuit court did not err in ruling that Issue 3 did not violate article 19, section 22. View "Steele v. Thurston" on Justia Law
Posted in:
Constitutional Law, Election Law
Stay Strong, Status Quo v. Bradford
The Supreme Court affirmed the circuit court's denial of Stay Strong, Status Quo's appeal of a certified election petition, holding that there was no error on the part of the circuit court.In this election petition, Stay Strong, Status Quo, a local-option ballot-question committee, and Bevans Family Limited Partnership (together, Stay Strong) opposed Van Buren County Clerk Pam Bradford's certification of a local-option petition sponsored by Local Option Ballot Question Committee Let Van Buren County Vote (Sponsor). The circuit court dismissed the certification appeal without holding a hearing. The Supreme Court affirmed, holding (1) the circuit court did not err by dismissing the appeal without first taking evidence or holding a hearing; (2) the circuit court did not err by concluding that the petition form was valid; (3) the circuit court did not err in finding that there were sufficient signatures for certification; and (4) Stay Strong's argument for reversal based on the timing of its statutory appeal was unavailing. View "Stay Strong, Status Quo v. Bradford" on Justia Law
Posted in:
Election Law
Mitchael v. State
The Supreme Court denied Petitioner's pro se petition for writ of habeas corpus, motion to recall mandate to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis, and joinder of claims, holding that Petitioner's claims did not establish grounds for the relief he sought.Petitioner was convicted of rape and terroristic threatening. The Supreme Court denied Petitioner's petition and motions, holding (1) Petitioner must first file his habeas corpus petition in the circuit court in the county where he was incarcerated; and (2) Petitioner did not satisfy any ground for granting a writ of coram nobis because he did not allege that there was any evidence extrinsic to the record that was hidden from the defense or that was unknown at the time of trial. View "Mitchael v. State" on Justia Law
Posted in:
Criminal Law
Bandy v. Vick
The Supreme Court reversed the judgment of the circuit court in favor of Plaintiff in this medical malpractice case, holding that the circuit court erred by striking and removing Defendants' constitutional right to a jury trial.Plaintiff filed a complaint alleging medical negligence against Defendants. The complaint included a demand for a jury trial. Defendants' answer also contained a demand for a jury trial. The circuit court struck Defendants' request to a jury trial as a sanction for failing to comply with its scheduling order's mediation requirement. After Plaintiff waived her right to a jury trial the matter proceeded to trial as a bench trial. The court entered judgment in favor of Plaintiff in the amount of $821,635. The Supreme Court reversed, holding that the circuit court lacked the authority to divest Defendants of their fundamental constitutional right to a jury trial. View "Bandy v. Vick" on Justia Law
Posted in:
Medical Malpractice
McKinney v. State
The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow Petitioner to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner's claim failed to establish cause to permit Petitioner to proceed in the trial court with a coram nobis petition.Petitioner was convicted of multiple drug-related offenses and sentenced to an aggregate 1848 months' imprisonment. In his coram nobis petition, Petitioner argued that the State committed a Brady violation. The Supreme Court denied the petition, holding that Petitioner failed to establish the State committed a Brady violation. View "McKinney v. State" on Justia Law
Posted in:
Criminal Law
McKee v. State
The Supreme Court affirmed Defendant's conviction of one count of rape, holding that there was no prejudicial error below.Specifically, the Supreme Court held (1) there was substantial evidence to support the jury's verdict; (2) the circuit court did not commit reversible error in denying Defendant's rape-shield motion; (3) any alleged error in the trial court's sustaining a hearsay objection was harmless; (4) the circuit court did not err in denying Defendant's motion to suppress evidence; (5) the circuit court did not err in denying Defendant's motion to allow a prior statement into the record; (6) the circuit court did not err in overruling Defendant's objection to the prosecutor's questions to the victim; and (7) there was no prejudicial error in the failure to add a transcription of the jury-selection proceedings in the record. View "McKee v. State" on Justia Law
Posted in:
Criminal Law