Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's convictions of first-degree murder, aggravated robbery, and theft of property, holding that the evidence was sufficient to support the convictions and that the circuit court did not abuse its discretion on a juror misconduct allegation.Specifically, the Supreme Court held (1) the circuit court did not err in denying Defendant's motion for directed verdict; (2) the circuit court did not abuse its discretion in not allowing Defendant to question a juror regarding her alleged head nod toward the victim's family after the jury had reached its verdicts in the guilt phase; and (3) the State rebutted the presumption of prejudice on the issue of whether the record was inadequate on jury questions during deliberations. View "Terry v. State" on Justia Law

The Supreme Court remanded this matter involving Defendant's motion for belated appeal, holding that the proper disposition of this case requires findings of fact, which must be made in the circuit court.Defendant was convicted of aggravated robbery and sentenced to 156 months' imprisonment. Defendant subsequently filed his motion requesting leave to proceed with a belated appeal of his conviction, arguing that he informed his retained trial counsel of his desire to appeal but that she did not file a notice of appeal. Defendant's lawyer disputed the account. The Supreme Court held that the proper disposition of the motion required findings of fact and therefore remanded the matter to the circuit court for an evidentiary hearing. View "Martin v. State" on Justia Law

The Supreme Court dismissed Defendant's appeal of the circuit court's dismissal of his petition to correct an illegal sentence, holding that the appeal must be dismissed because the petition was filed in the circuit court presiding over the county of Defendant's incarceration, rather than the court of conviction.Defendant was convicted by a Pulaski County jury of rape. Defendant was incarcerated at the Pine Bluff Unit of the Arkansas Department of Correction in Jefferson County when he filed a petition to correct an illegal sentence in the Jefferson County Circuit Court. The Supreme Court dismissed the appeal for lack of jurisdiction, holding that the Jefferson County Circuit Court lacked jurisdiction to consider the petition. View "Clark v. Kelley" on Justia Law

The Supreme Court denied Defendant's petition for permission to file a writ of error coram nobis in the trial court, holding that the petition contained no allegations of trial error warranting coram nobis relief.Defendant was convicted of drug-related offenses and was sentenced as a habitual offender to an aggregate sentence of 2,200 months' imprisonment. The conviction was affirmed on appeal. Defendant sought permission to petition for writ of error coram nobis, asserting trial error in admitting evidence of his prior felony convictions and a violation of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the petition, holding that Defendant's claims did not establish grounds for the writ. View "Von Holt v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of habeas corpus pursuant to Act 1780 of 2001, Ark. Code Ann. 16-112-201 to -208, holding that because Appellant had already raised the same issue in an earlier petition, the circuit court did not err when it declined to grant the writ.In 1992, Appellant was found guilty of rape and theft of a van and sentenced to forty years' imprisonment. In 2015, Appellant filed his first habeas petition seeking testing on vaginal swabs of the victim. The circuit court denied relief, and the Supreme Court affirmed. In 2018, Appellant filed a second petition for writ of habeas corpus again seeking DNA testing of a vaginal swab recovered from the victim. The circuit court denied relief. The Supreme Court affirmed, holding that where Appellant already raised his claim to the circuit court and it was rejected on appeal, he was not entitled to relief on the same allegation in the subsequent petition. View "Makkali v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus, holding that there was no error.Specifically, the Supreme Court held that the circuit court correctly denied Appellant's claim that he was being illegally detained because (1) by raising the same allegations that Appellant had already considered, Appellant abused the writ; (2) Appellant did not establish that there was error in the judgment of conviction that deprived the trial court of jurisdiction in the matter or rendered the judgment invalid; and (3) the fact that the circuit court permitted Appellant to proceed with his habeas petition without paying a filing fee was not tantamount to issuance of the writ. View "Anderson v. Kelley" on Justia Law

In this appeal returning to the Supreme Court for a third time challenging an award of attorney's fees to Plaintiff in his illegal exaction lawsuit that successfully challenged the constitutionality of certain legislative acts (Acts), the Supreme Court held that the circuit court properly awarded attorney's fees.In his illegal exaction complaint Plaintiff alleged that the challenged Acts were unconstitutional. The trial court ultimately granted judgment in favor of Plaintiff. The parties then began sparring over attorney's fees. The circuit court eventually awarded attorney's fees but denied Plaintiff's request for prejudgment interest. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in awarding $323,266 in attorney's fees and did not err when it denied Plaintiff prejudgment interest. View "Walther v. Wilson" on Justia Law

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for writ of habeas corpus seeking scientific testing of evidence from his criminal case, holding that Appellant failed to establish the timeliness of the petition or its merit.Appellant was found guilty in 1994 of capital murder with the underlying offenses of kidnapping and rape and was sentenced to life imprisonment without parole. In 2019, Appellant filed the instant petition for scientific testing of evidence pursuant to Ark. Code Ann. 16-112-201 to -208. The trial court denied the petition. The Supreme Court affirmed, holding (1) Appellant did not establish by clear and convincing evidence that no reasonable fact-finder would find him guilty of the murder of the victim based on any specific testing; (2) Appellant did not satisfy any of the factors that would establish that his petition was timely; and (3) the trial court was not obligated to hold a hearing on the petition. View "Mills v. State" on Justia Law

The Supreme Court reversed the ruling of the circuit court denying the motion filed by Asa Hutchinson, the Governor of the State of Arkansas, to dismiss an action filed by Appellee, an inmate in the Arkansas Department of Correction, holding that the complaint was barred by sovereign immunity.Appellee filed a complaint challenging the constitutionality of the Fair Sentencing of Minors Act of 2017 (FSMA), codified at Ark. Code Ann. 16-93-621, alleging that the FSMA denied him equal protection and due process of law, subjected him to cruel and unusual punishments, and violated the Americans with Disabilities Act. The circuit court dismissed the action with respect to all defendants except Hutchinson in his official capacity. The Supreme Court reversed, holding that the circuit court erred in ruling that Appellee pleaded sufficient facts to overcome Hutchinson's defense of sovereign immunity. View "Hutchison v. Mcarty" on Justia Law

In a certified question of law regarding the requirement for creditors to comply strictly with the Arkansas Statutory Foreclosure Act the Supreme Court held that Ark. Code Ann. 18-50-104(b)(4) requires disclosure of the specific default under the terms of the mortgage agreement.The Court by the United States Bankruptcy Court for the Western District of Arkansas certified the question of law to the Supreme Court, asking whether mere acknowledgment that a default has occurred is sufficient for the trustee's Notice of Default and Intention to Sell or whether section 18-5-104(b)(4) requires the trustee's notice of default to set forth the default for which foreclosure is made. The Supreme Court answered that the statute requires that the notice must state the specific default that occurred. View "Davis v. Pennymac Loan Services, LLC" on Justia Law