Justia Arkansas Supreme Court Opinion Summaries

The case revolves around the appellant, Jacovan Bush, who was convicted of capital murder, aggravated residential burglary, aggravated robbery, and theft of property. The charges stemmed from an incident where men broke into Devon Howard's apartment and killed him. Bush was arrested after his blood was found at the crime scene and matched the DNA samples. Bush's defense argued that the blood stains were dry when found, suggesting they were shed before the murder. However, a crime-scene specialist testified that a specific blood sample was fresh when she arrived but had dried by the time law enforcement finished clearing the scene.Prior to the trial, Bush had moved to exclude the crime-scene specialist's testimony, arguing it was improper expert testimony. The circuit court denied this motion. During the trial, the State presented several witnesses, including the crime-scene specialist, who testified about the blood evidence. After the State rested, Bush moved for a directed verdict on all counts, which the circuit court denied. The jury found Bush guilty on all counts, and he was sentenced to life imprisonment without parole, plus an additional forty years.On appeal, Bush argued that the circuit court erred in denying his motion for a directed verdict due to insufficient evidence and in denying his motion to exclude the crime-scene specialist's testimony. The Supreme Court of Arkansas affirmed the lower court's decision, holding that there was substantial evidence to support the convictions and that the circuit court did not abuse its discretion in admitting the crime-scene specialist's testimony. The court noted that the jury could have reasonably concluded that Bush was in the apartment around the time of the murder based on the DNA evidence and the testimony about the blood's condition. View "BUSH v. STATE OF ARKANSAS" on Justia Law

This case involves a dispute between Union Pacific Railroad Company and its employee, Randy G. Franklin. Franklin, a long-time employee of Union Pacific, brought a gun to work and stored it in his locked vehicle, which was parked in Union Pacific's parking lot. This action was in compliance with Arkansas law, but violated Union Pacific's company policy that bans employees from carrying firearms onto its property. As a result, Union Pacific terminated Franklin's employment, which was later reduced to a lengthy suspension by an arbitration panel.Union Pacific filed a declaratory-judgment action in federal court, seeking a declaration that Arkansas Code Annotated section 11-5-117, which allows employees to store firearms in their vehicles on their employer's property, is preempted by the Federal Employers’ Liability Act (FELA) when applied to Union Pacific parking lots in Arkansas. Franklin counterclaimed, seeking a declaratory judgment that Union Pacific must allow him to bring his firearm onto railroad property, as long as the firearm is legally possessed for a lawful purpose and stored out of sight in his locked car.The United States District Court for the Eastern District of Arkansas certified a question to the Supreme Court of Arkansas: whether the prohibitions in Arkansas Code Annotated section 11-5-117 are severable from the liability-immunity provisions in section 16-120-802(a) such that section 11-5-117 would still apply when the liability-immunity provisions of section 16-120-802(a) cannot apply.The Supreme Court of Arkansas answered the certified question in the affirmative. The court found that section 11-5-117, which protects the rights of employees to store firearms in their vehicles on their employer's property, is not dependent on the liability-immunity provisions of section 16-120-802. Therefore, even if the latter is preempted by FELA, section 11-5-117 is not likewise preempted. The court concluded that regardless of whether FELA preempts section 16-120-802(a), section 11-5-117 still applies. View "UNION PACIFIC RAILROAD COMPANY V. FRANKLIN" on Justia Law

The appellant, Daryl Jason Scarbrough, was convicted of capital murder and aggravated robbery by the Pulaski County Circuit Court and sentenced to life imprisonment with an additional forty-year term. Scarbrough appealed the decision, arguing that the circuit court erred in granting the State's motions for continuance, denying his motion for continuance, denying his motion to suppress, allowing prejudicial remarks by the prosecutor, and admitting a map into evidence.The case revolved around the murder of David Dunn. Scarbrough was identified as a suspect and was arrested on an active parole-absconder warrant. He was found hiding in a flower bed, and his jeans, which had blood stains, were seized and sent for DNA testing. The DNA matched that of the victim and an unknown male. The State charged Scarbrough with capital murder and aggravated robbery.Scarbrough filed a motion to suppress the DNA evidence, arguing that the police had collected and examined the evidence without a search warrant. The State countered that Scarbrough was lawfully arrested on active warrants and that the clothes were seized pursuant to a search incident to arrest. The circuit court denied Scarbrough's motion to suppress the blood evidence.At trial, the prosecutor referred to Scarbrough as a "homicidal hitchhiker" during the opening statement. Scarbrough objected and moved for a mistrial, which was denied by the circuit court. The court also admitted into evidence a map made by AT&T showing the location of cell-phone pings made from the victim's phone shortly after his murder.The Supreme Court of Arkansas affirmed the circuit court's decision. It held that the circuit court did not abuse its discretion in granting the State's motions for continuance and denying Scarbrough's motion for continuance. It also found that the circuit court did not err in denying Scarbrough's motion to suppress the blood evidence, allowing the prosecutor's remarks, and admitting the map into evidence. The court reviewed the record for all errors prejudicial to Scarbrough, as required by Arkansas Supreme Court Rule 4-3(a), and found no reversible error. View "SCARBROUGH v. STATE OF ARKANSAS" on Justia Law

In 2018, John Patrick Cullen pleaded nolo contendere to second-degree sexual assault and was sentenced to seventy-two months' imprisonment. He did not appeal his conviction or sentence. In 2021 and 2022, Cullen filed petitions for writ of error coram nobis and writ of habeas corpus in the Garland County Circuit Court, alleging his innocence based on new evidence. This evidence included statements from the victim, Kathi Brinkley, which Cullen claimed contained factual errors, and an admission from a second individual, Kati Knight, that she did not witness the assault. Cullen also argued that the affidavit supporting his arrest contained fabrications by Brinkley.The Garland County Circuit Court denied Cullen's petitions, finding that he had failed to state a cause of action upon which relief could be granted and had not asserted any grounds for which he could successfully pursue these claims. Cullen appealed this decision to the Supreme Court of Arkansas.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that Cullen's claim of actual innocence was not cognizable under current law and that his allegations regarding Knight's admissions had been abandoned on appeal. Therefore, the court held that the lower court did not abuse its discretion in denying Cullen's petition for writ of error coram nobis. Regarding the writ of habeas corpus, the court found that Cullen had failed to state a colorable claim under the relevant statute and had not alleged that his sentence was illegal or that the trial court lacked subject-matter jurisdiction. Furthermore, the court concluded that the lower court did not have personal jurisdiction to issue a writ even if Cullen had stated a legitimate ground for relief, as his second habeas petition was not filed in the correct jurisdiction. View "CULLEN v. STATE OF ARKANSAS" on Justia Law

The case involves Damien Echols, one of the "West Memphis Three," who was convicted for the murder of three eight-year-old boys in 1993. Echols, along with Jason Baldwin and Jessie Misskelley, were found guilty, with Echols receiving a death sentence. In 2011, Echols entered an Alford plea, maintaining his innocence but acknowledging the prosecution's evidence, and was released from prison. Echols sought further DNA testing of the evidence using new technology, arguing that it could potentially identify the true perpetrator(s) of the crime.Previously, the Crittenden County Circuit Court denied Echols's petition for additional DNA testing under Act 1780, ruling that the court lacked jurisdiction as Echols was not in State custody. The court interpreted Act 1780 as a form of habeas corpus relief, traditionally available only to those in State custody. Echols appealed this decision, arguing that the plain language of Act 1780 allows any person convicted of a crime to petition for additional DNA testing to demonstrate actual innocence, regardless of their custody status.The Supreme Court of Arkansas reversed and remanded the lower court's decision. The court found that the plain language of Act 1780 unambiguously permits "a person convicted of a crime" to petition for additional DNA testing to demonstrate actual innocence. The court held that the lower court had misinterpreted the plain language of Act 1780 by imposing a requirement that a petitioner must be in State custody to seek relief under the Act. The court concluded that Echols, as a person convicted of a crime, was entitled to seek relief under Act 1780, regardless of his custody status. View "ECHOLS v. STATE OF ARKANSAS" on Justia Law

In Arkansas, attorney Chris Corbitt and other plaintiffs sought to challenge the prohibition of firearms in courthouses. Corbitt had previously attempted to bring a firearm into the Pulaski County District Courthouse and the Juvenile Justice Complex, but was denied. He filed a complaint, which was dismissed by the circuit court and later affirmed by the Supreme Court of Arkansas. Despite this, Corbitt and other plaintiffs filed another complaint after encountering firearm restrictions in a different courthouse. This complaint was also dismissed.The circuit court ruled that Corbitt was not entitled to injunctive relief, declaratory judgment, or a writ of mandamus. The court also found that even if issue preclusion were not applicable, it would rule similarly to Judge Wright’s decision regarding the interpretation of Arkansas Code Annotated section 5-73-122. The court rejected the plaintiff’s argument, stating that it was based on a flawed premise that misread the plain meaning of the statute and ignored the importance of Amendment 80 to the Arkansas Constitution. The circuit court emphasized that Amendment 80 gives the Arkansas Supreme Court the power to regulate court procedure, including the discretion to determine when weapons should be allowed in courtrooms.The Supreme Court of Arkansas held that Corbitt was collaterally estopped from pursuing his claims due to the previous litigation, but the remaining plaintiffs could proceed. The court further held that attorneys, as officers of the court, are authorized by statute to possess handguns in courthouses. The court reversed the circuit court’s denial of the petition for a declaratory judgment as it pertains to the remaining plaintiffs and remanded for further proceedings consistent with this opinion. View "CORBITT v. PULASKI COUNTY CIRCUIT COURT" on Justia Law

The case revolves around the conviction of Leashebia Davis for capital murder. The incident occurred on May 4, 2020, when Elvis Kendal was shot and killed. Davis was charged with capital murder on July 1, 2020, and was later convicted by a Jefferson County Circuit Court jury on May 17, 2023. She was sentenced to life imprisonment without the possibility of parole. The case was based on the testimonies of multiple witnesses, including Natasha Gill, a cousin of the victim, who witnessed the shooting, and Roderick Breedlove and Michael Brazell, who were with Davis in the vehicle at the time of the incident. The testimonies varied, with Davis and Breedlove implicating Brazell as the shooter, while Brazell testified that Davis was the shooter.The Jefferson County Circuit Court found Davis guilty of capital murder. Davis appealed the decision, arguing that there was insufficient evidence to support her conviction and that the court erred in denying her motion for a new trial based on juror misconduct. The court denied her motion for a new trial, asserting that Davis failed to demonstrate that the juror in question engaged in misconduct.The Supreme Court of Arkansas affirmed the lower court's decision. The court found substantial evidence to support Davis's capital murder conviction, including the testimonies of witnesses and the video-surveillance footage. The court also held that Davis failed to prove that the juror engaged in misconduct, as there was no evidence that the juror was dishonest during the jury-selection process or had any relationship with Davis's defense attorney. The court concluded that the lower court did not abuse its discretion by denying Davis's motion for a new trial. View "Davis v. State" on Justia Law

Jessie Hill, a prisoner serving life imprisonment without parole for capital murder and an additional 720 months for first-degree murder, filed multiple pro se petitions for writ of habeas corpus. He claimed double jeopardy, violations of his right to due process, insufficient evidence supporting his convictions, and other obscure claims. The Jefferson County Circuit Court dismissed his petitions, noting that Hill's pleadings were often illegible and contained profane language. The court concluded that Hill failed to establish that he was being illegally detained.Hill had previously filed multiple petitions for postconviction relief, including four habeas corpus petitions, all of which were denied by the circuit court and affirmed on appeal. In his current appeal, Hill argued that his convictions violated the prohibition against double jeopardy, that the charging informations were defective and violated his right to due process, and that there was insufficient evidence to support his convictions.The Supreme Court of Arkansas affirmed the circuit court's decision, stating that Hill's claims did not challenge the legality of his sentences or the subject-matter jurisdiction of the trial courts that entered the judgments of conviction. The court noted that a habeas proceeding does not afford a petitioner an opportunity to retry his case and is not a substitute for raising an issue either at trial or on direct appeal. The court concluded that Hill's double-jeopardy claim failed to state a basis for habeas relief, and his sufficiency-of-the-evidence claims represented an abuse of the writ as he had raised these claims in his previous habeas petitions. View "Hill v. Payne" on Justia Law

Eddie Lee Patrick, Jr., a prisoner, appealed the denial of his pro se petition for a writ of habeas corpus by the Jefferson County Circuit Court. Patrick was convicted of rape and terroristic threatening in the first degree by a Jefferson County jury in 2003 and was sentenced to 480 months' imprisonment. His conviction was affirmed by the Arkansas Court of Appeals. Patrick's petition for habeas corpus relief was based on pretrial DNA testing that he claimed proved his innocence.The Jefferson County Circuit Court denied Patrick's petition, and he appealed to the Supreme Court of Arkansas. Patrick argued that the lower court erred in not granting him habeas relief because the DNA evidence established his actual innocence. He also claimed that because the lower court allowed him to proceed in forma pauperis (without payment of a fee), it essentially held that the writ should be issued.The Supreme Court of Arkansas affirmed the lower court's decision. The court found that while the DNA report showed that Patrick's DNA was not present, the jury was aware of this evidence and still found him guilty. The court also noted that Patrick did not meet the requirements to state a prima facie claim under Act 1780, as he did not seek specific scientific testing of evidence that was not available at the time of trial nor allege the existence of new scientific methods to retest evidence that was available at the time of trial. The court concluded that Patrick's claim for habeas relief was merely a challenge to the sufficiency of the evidence supporting his conviction. The court also rejected Patrick's argument about proceeding in forma pauperis, stating that being allowed to file a petition without paying a fee does not equate to the issuance of the writ. View "Patrick v. Payne" on Justia Law

David Stewart, an inmate, appealed the denial of his pro se petition for a writ of habeas corpus. He argued that his conviction for two counts of sexual assault violated the prohibition against double jeopardy and that a condition of his incarceration, requiring him to complete the Reduction of Sexual Victimization Program (RSVP), made his sentencing order illegal. Stewart also filed a motion for default judgment, claiming that the respondent failed to respond to his petition.The Jefferson County Circuit Court found that the sentencing order was not illegal on its face and that Stewart was not entitled to a default judgment on his petition for the writ. The court noted that Stewart was originally charged with one count of rape and one count of sexual assault, indicating distinct impulses involved in each charge of sexual assault. The court also found that the RSVP requirement was often imposed as a condition of parole or suspended imposition of sentence (SIS), not incarceration.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that Stewart failed to demonstrate that the sentencing order was illegal on its face or that the trial court lacked jurisdiction to convict him of separate counts of second-degree sexual assault. The court also found that Stewart failed to show that the RSVP requirement and the no-contact order were part of his incarceration rather than his suspended sentence. Lastly, the court ruled that the circuit court did not err in denying Stewart's motion for a default judgment, as the Arkansas Rules of Civil Procedure do not apply to a postconviction habeas proceeding. View "Stewart v. Payne" on Justia Law