Justia Arkansas Supreme Court Opinion Summaries

In this case, the Supreme Court of Arkansas was asked to consider an appeal by Maurice Trammel, who was challenging the denial of his petition to proceed in forma pauperis in seeking a declaratory judgment and a writ of mandamus. Trammel had been sentenced to 240 months' imprisonment for various crimes and was designated as a habitual offender. He sought to challenge his habitual offender status, arguing that there was no proof offered by the State that demonstrated he had committed the necessary number of felonies to be classified as such. He further argued that his sentence should be declared illegal, which would effectively reduce his period of parole eligibility.The Supreme Court of Arkansas held that Trammel did not state a colorable cause of action and that his petition was effectively a collateral attack on his sentence, which should have been raised in timely postconviction petitions. The court noted that Trammel was charged as a habitual offender and pleaded guilty to all the charges, including his habitual-offender status. His challenge to the sufficiency of the evidence supporting his habitual offender status was not a jurisdictional issue and was therefore waived by his guilty plea. Moreover, the court observed that the Department of Correction had no authority to modify a sentence imposed by a circuit court.Hence, the court affirmed the circuit court's denial of Trammel's in forma pauperis petition, finding no abuse of discretion in the circuit court's conclusion that Trammel had failed to state a justiciable controversy that would entitle him to declaratory relief. View "TRAMMEL v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

In the Supreme Court of Arkansas case, Jeffery Allen Workman was convicted of first-degree murder, aggravated residential burglary, and second-degree battery, and sentenced to consecutive sentences of life in prison. The charges originated from an incident where Workman broke into a residence to retrieve a computer and in the process, shot and killed a man named David Basham. On appeal, Workman argued that the State failed to provide substantial evidence that he committed first-degree murder. However, the Supreme Court found that Workman failed to properly preserve this issue for appeal, as he did not renew his motion for a directed verdict at the close of all the evidence as required by the Arkansas Rules of Criminal Procedure. Therefore, the court affirmed his convictions. Additionally, the court conducted a Rule 4-3(a) review due to Workman's life imprisonment sentence and found no reversible error. View "WORKMAN, v. STATE OF ARKANSAS" on Justia Law

In this case heard by the Supreme Court of Arkansas, Jacoby Goehler was convicted by a jury for the first-degree murder of Davidlee Stansbury and sentenced to life in prison plus fifteen years. Goehler appealed his conviction on several grounds including the admission of incriminating statements made in police custody without his attorney present, denial of his motion to change venue, admission of testimony from his wife, and admission of a photograph of the victim. He also disputed the court's refusal to provide jury instructions on lesser-included offenses of manslaughter and second-degree murder.The Supreme Court of Arkansas affirmed the lower court's decision on each point. The Court stated that Goehler failed to preserve his argument about his incriminating statements for appeal. It held that the trial court did not abuse its discretion in denying a change of venue because the court was able to select an impartial jury. It also found that the spousal privilege did not apply to the testimony of Goehler's wife because the facts she testified about were not privileged. The Court ruled that the admission of the photograph of the victim was not an abuse of discretion because it aided the jury in understanding the consequence of Goehler's actions. Lastly, the Court found no error in the trial court's refusal to provide jury instructions on manslaughter and second-degree murder because there was no rational basis for acquitting Goehler of first-degree murder and instead convicting him of the lesser offenses. View "GOEHLER v. STATE OF ARKANSAS" on Justia Law

In the case before the Supreme Court of Arkansas, the appellant, Cordale Stacy, was convicted of three counts of capital murder and sentenced to life imprisonment without parole on each count, along with a consecutive fifteen years’ imprisonment for a firearm enhancement. The appellant argued that the circuit court erred in denying his motions to dismiss the capital-murder charges due to an alleged overlap of capital, first-degree, and second-degree murder statutes.The case arose from a shooting incident in a Forrest City apartment where three individuals, an adult and two children, were found deceased. Witnesses identified Stacy fleeing the scene and further investigations led to his arrest. Stacy was charged with three counts of capital murder, possession of a firearm by certain persons, and a felony-with-a-firearm enhancement.Stacy filed two motions to quash the felony information, arguing that the capital murder statute overlapped with the first-degree murder statute for the adult victim, and overlapped with the first-degree and second-degree murder statutes for the minor victims. He contended that this overlap exposed him to an impermissible uncertainty in the offenses, which should have led to their dismissal. The circuit court denied both motions.On appeal, the Supreme Court of Arkansas held that there was no constitutional infirmity in the overlap of these statutes. The Court noted that each offense set forth different elements to be proved by the State, and thus, any alleged overlap presented no constitutional issues. Furthermore, the Court affirmed that the discretion of the prosecutor to choose between overlapping offenses did not violate the Equal Protection or Due Process Clauses. Therefore, the Court affirmed the circuit court's denial of Stacy's motions to quash the felony information and dismiss the charges. As a result, Stacy's conviction and sentence were upheld. View "STACY v. STATE OF ARKANSAS" on Justia Law

In this case, the Supreme Court of Arkansas affirmed the denial of declaratory judgment and writ of mandamus petitions filed by Charles Sims, an inmate in the Arkansas Department of Correction (ADC). Sims had sought a declaration that he was eligible for parole, contrary to the determination made by ADC. The court affirmed the circuit court's finding that Sims was ineligible for parole according to the Arkansas Code.Sims had pleaded guilty to first-degree murder in 1995 and was paroled in 2007. In 2010, he pleaded guilty to first-degree battery and kidnapping, and was sentenced to concurrent terms of 180 months' imprisonment to run concurrently with his remaining sentence for first-degree murder. ADC records applied section 16-93-609 to Sims’s sentence for battery and kidnapping, determining him ineligible for parole.The court held that Sims had failed to establish a justiciable controversy or that he had a legal interest in the controversy, two prerequisites for declaratory relief. The court also noted that parole eligibility determinations fall within the purview of ADC, not the judiciary. The court further held that the absence of a reference to the parole-eligibility statute in the judgment did not constitute a requirement for parole eligibility.The court also dismissed Sims's argument that section 5-4-501(d)(2) was inapplicable to him, holding that the court has applied the relevant sections when the prior conviction consisted of only one offense. The court concluded that Sims had not established a right to parole eligibility, and therefore had no basis for the issuance of a writ of mandamus. The court affirmed the circuit court's decisions, ruling it did not clearly err or abuse its discretion when it denied and dismissed Sims's petitions for declaratory judgment and writ of mandamus. View "SIMS v. DEXTER PAYNE, DIRECTOR, ARKANSAS DEPARTMENT OF CORRECTION" on Justia Law

The Supreme Court dismissed Appellant's appeal from the dismissal of his petition for writ of habeas corpus under Ark. Code Ann. 16-112-101, holding that the circuit court did not err in dismissing the petition.The circuit court dismissed Appellant's habeas petition for lack of personal jurisdiction because Appellant was incarcerated in Lincoln County when he initially filed his petition but was transferred to the Grimes Unit in Jackson County before the court entered its order. The Supreme Court dismissed Appellant's appeal, which rendered his motions for default judgment and to make a ruling moot, holding that a writ of habeas corpus issued by the Lincoln County Circuit Court could not be returned because he was no longer within its jurisdiction. View "Thompson v. Payne" on Justia Law

The Supreme Court dismissed Appellant's appeal from the dismissal of his petition for writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that the circuit court properly dismissed the petition for lack of personal jurisdiction.Appellant was incarcerated in Jefferson County when he filed his petition for a writ of habeas corpus. He was transferred to the East Arkansas Regional Unit in Lee County before the circuit court entered its order dismissing the petition. The Supreme Court dismissed this appeal, holding that a writ of habeas corpus issued by the Jefferson County Circuit Court could not be returned because Appellant was no longer within the court's jurisdiction. View "Davis v. Payne" on Justia Law

In this fifth appeal before the Supreme Court regarding a class action lawsuit stemming from two circuit court orders denying Appellant's motion to enforce arbitration agreements and its motion to compel class members with arbitration agreements to submit their claims to binding arbitration, holding that remand was necessary.After the Supreme Court's ruling in Phillips II, Appellant filed a motion to enforce arbitration agreements and to compel 197 residents with arbitration agreements to submit their claims to binding arbitration. After the ruling in Phillips III, Appellant moved to enforce arbitration agreements and to compel thirty-three residents with arbitration agreements to submit their claims to binding arbitration. The court entered an order with respect to both motions, from which Appellant appealed. The Supreme Court remanded the case with instructions, holding that the circuit court failed to provide the Supreme Court with specific findings with respect to each arbitration agreement and individual resident and that such findings were necessary for the Court to conduct a proper appellate review. View "Robinson Nursing & Rehabilitation Center, LLC v. Phillips" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition for leave to proceed in forma pauperis, for extraordinary writ, and to set aside and vacate his judgment, holding that Appellant failed to allege facts to support his claim that he was entitled to an extraordinary writ or to have his sentence vacated.Appellant pled guilty to second degree sexual assault and sentenced to seventy-two months' imprisonment. Appellant later filed a petition for leave to proceed in forma pauperis seeking to file an extraordinary writ to change his sex-offender registration agency. Appellant also filed a motion to set aside or vacate judgment. The circuit court denied hisrelief. The Supreme Court affirmed, holding that the circuit court did not err in finding that Appellant failed to state a cause of action upon which relief could be granted and that the petitions failed to assert any grounds for which Appellant could successfully pursue those claims. View "Cullen v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court dismissing Petitioner's petition for a writ of habeas corpus, holding that the circuit court did not err in concluding that Petitioner had failed to state a ground for the writ.Petitioner pled guilty to rape and aggravated robbery and was sentenced as a habitual offender. In his habeas corpus petition, Petitioner alleged that he was innocent of the offense of rape, that the State maliciously applied the habitual offender statute in violation of the Eighth Amendment, and that the Arkansas statute requiring that he serve 100 percent of his sentence was unconstitutional. The circuit court found that the claims were not cognizable in habeas and noted that parole eligibility falls within the domain of the executive branch. The Supreme Court affirmed, holding that the circuit court did not err. View "White v. Payne" on Justia Law