Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the circuit court dismissing Appellant's action against Baptist Health appellees and John Hearnsberger, M.D., holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of disputed discovery.Appellant, a surgeon, was on the medical staff of Baptist Health from 2003 until 2011, when his appointment and clinic privileges at Baptist Health Medical Center-Little Rock were terminated, effective immediately. Baptist Health also reported the suspension of Appellant's clinical privileges to the Arkansas State Medical Board, which, in 2014, revoked Appellant's license. Appellant appealed the revocation, and his license was reinstated. In 2011, Appellant filed a lawsuit against Baptist Health and several individuals, asserting several claims. The circuit court entered a consent order dismissing the Medical Board and Dr. Hearnsberger in his official capacity. The circuit court then granted summary judgment on Appellant's remaining claims. The Supreme Court reversed in part, holding that the circuit court abused its discretion in denying Appellant's motions to compel production of two types of discovery, and the discovery error was not harmless as to Appellant's discrimination and tortious-interference claims. View "Williams v. Baptist Health" on Justia Law

The Supreme Court affirmed Appellant's conviction of capital murder, holding that the evidence was sufficient to sustain the conviction and that the circuit court did not err in denying Appellant's motion to suppress tracking data generated by his cellphone.On appeal, Appellant argued that the trial court erred by denying his directed-verdict motion because the evidence supported the defense's theory of the case that he did not intend to shoot the victim. Further, Appellant argued that the court abused its discretion in denying his motion to suppress evidence obtained from the seizure of AT&T phone records. The Supreme Court disagreed, holding (1) the evidence was sufficient to support the capital murder conviction; and (2) the circuit court correctly denied the motion to suppress. View "Thomas v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's petition to proceed in forma pauperis on a petition for writ of mandamus and a motion for declaratory judgment, holding that Appellant failed to state a colorable cause of action.In 1998, Appellant was convicted of rape. In his petition for a writ of mandamus, Appellant asserted that he sought information pursuant to the Arkansas Freedom of Information Act regarding his rape conviction but received no response. The circuit court denied the petition. The Supreme Court affirmed, holding (1) even if Appellant had requested disclosable information, he would not be entitled to inspect it as an incarcerated person; and (2) Appellant did not demonstrate a legitimate claim given the facts presented and therefore failed to establish a colorable cause of action to support his request to proceed in forma pauperis. View "Berger v. Bryant" on Justia Law

The Supreme Court denied Appellant's appeal from the order of the circuit court denying his petition to proceed in forma pauperis on the grounds that Appellant failed to state a colorable cause of action in a petition for writ of habeas corpus, holding that the circuit court did not abuse its discretion by denying Appellant's in forma pauperis petition.In his habeas petition, Appellant alleged that the trial court lacked jurisdiction in his criminal case. Before this case was submitted to the Supreme Court, Appellant filed two motions, including a "Judicial Notice of a Void Judgment" and a "Notice to the Court." The Supreme Court denied the motions, holding that neither motion was cognizable under the Court's rules. The Court then affirmed the Supreme Court's denial of Appellant's in forma pauperis petition, holding that the circuit court correctly found that Appellant did not assert a colorable cause of action. View "Chatmon v. Kelley" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's orders denying her motions to declare Ark. Code Ann. 5-62-106 (disposition of animal) and Ark. Code Ann. 5-62-111 (prevention of cruelty) unconstitutional and conditionally granting her motion for return of seized property, holding that there was no final, appealable order in this case.Appellant was convicted of thirty-one misdemeanor counts of cruelty to animals. The circuit court subsequently dismissed the charges on speedy-trial grounds. The State appealed, and the Supreme Court dismissed the appeal on the grounds that it was not authorized. Appellant had filed motions seeking a declaration that sections 5-62-106 and -111 are unconstitutional and seeking the return of her seized property. The circuit court denied the constitutional claims and entered a conditional order granting Appellant's motion for return of seized property. Appellant appealed. The Supreme Court dismissed the appeal, holding that because the conditional order did not make specific findings as to the return of the property or as to damages and because it expressly left open the possibility of further proceedings, there was no final, appealable order in this case. View "Siegel v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's pro se petition for writ of habeas corpus, holding that the circuit court did not err in denying the petition.Appellant was found guilty of two counts of delivery of a controlled substance and one count of maintaining a drug premises. In his habeas petition, Appellant argued that he was actually innocent because his arrest and conviction was based on the false testimony of a witness who had a lengthy criminal history. Appellant further argued that the writ should issue because he was not afforded effective assistance of counsel. The circuit court denied the petition. The Supreme Court affirmed, holding (1) Appellant's claims regarding the witness's credibility do not constitute a valid assertion that he was being unlawfully detained; and (2) Appellant did not actually connect an allegation of ineffective assistance of counsel to his allegation that he was unlawfully detained. View "Cave v. State" on Justia Law

The Supreme Court denied Petitioner's second petition requesting permission to proceed in the trial court with a petition for writ of error coram nobis, holding that Petitioner's proposed attack on the judgment had no merit.Petitioner was convicted of raping a mentally handicapped sixteen-year-old girl and was sentenced to life imprisonment. In his first petition for writ of error coram nobis Petitioner alleged a number of errors in the trial procedure. The first petition was denied. In his second coram nobis petition, Petitioner alleged violations of Brady v. Maryland, 373 U.S. 83 (1963). The Supreme Court denied the writ, holding that Petitioner failed to meet his burden of demonstrating a fundamental error of fact extrinsic to the record. View "McClinton v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for leave to file a petition for writ of error cram knobs, holding that the circuit court did not abuse its discretion in declining to issue the writ.Appellant pled guilty to rape and was sentenced as a habitual offender to 720 months' imprisonment. In his coram nobis petition, Appellant alleged several grounds for relief, including claims of actual innocence, an invalid arrest warrant, a coerced guilty plea, and prosecutorial misconduct. The circuit court denied the motion. The Supreme Court affirmed, holding that Appellant did not demonstrate that that the writ should issue and failed diligently to proceed on his claim for coram nobis relief. View "Carroll v. State" on Justia Law

The Supreme Court reversed the vacated the opinion of the court of appeals affirming the decision of the Arkansas Workers' Compensation Commission affirming and adopting the findings of the administrative law judge (ALJ) awarding an additional-benefits claim to Bruce Menser, holding that Menser's additional-benefits claim was time barred by the statute of limitations.At the time Menser requested a hearing before the Commission, he was receiving workers' compensation benefits. The ALJ found that Menser sustained compensable brain and neuropathy injuries during the course and scope of his employment and that the statute of limitations did not bar Menser's claim for additional medical benefits because it had been tolled. The Commission affirmed and adopted the ALJ's decision. The court of appeals affirmed. The Supreme Court reversed, holding that the Commission erred in determining that Menser's claim for additional medical benefits sufficiently tolled the statute of limitations, and to the extent that Arkansas case law does not comport with this holding, those cases are overruled. View "White County Judge v. Menser" on Justia Law

The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that because Appellant did not establish either that the sentencing orders implicated the jurisdiction of the circuit court or that they were facially invalid, the circuit court did not err in denying the petition.The circuit court denied Appellant's petition on the basis that Appellant had previously raised the same arguments in a prior habeas petition. The Supreme Court affirmed but on different grounds, holding (1) the circuit court clearly erred in determining that Appellant's Fair Sentencing of Minors Act claims were previously considered, but because Appellant's challenge was to his parole eligibility, he failed to establish that the writ should issue; and (2) Appellant's argument that his sentence was a grossly disproportionate punishment was not cognizable in a writ of habeas corpus. View "Proctor v. Payne" on Justia Law