Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the order of the circuit court denying Appellant's petition to proceed in forma pauperis in a civil rights and medical malpractice lawsuit, holding that the circuit court improperly relied upon the statutory burden of proof for medical malpractice claims when determining that Appellant's complaint failed to state a colorable cause of action.The circuit court concluded that Appellant established indigence but found that the underlying complaint failed to state a colorable cause of action because Appellant failed to comply with the statutory burden of proof in medical malpractice cases. The Supreme Court reversed, holding that the circuit court erred in relying on Ark. Code Ann. 16-114-206 in determining whether Appellant's complaint stated a colorable cause of action. View "Harmon v. Bland" 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 filed under Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law.Appellant was convicted of two counts of capital murder and, in a separate trial, one count of second-degree murder. In his habeas corpus petition, Appellant alleged that the judgment of conviction for capital murder was void because he was detained without lawful authority. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's request for habeas relief was clearly without merit. View "Hall v. Kelley" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's petition to correct an illegal sentence "imposed in an illegal manner," filed pursuant to Ark. Code Ann. 16-90-111, holding that the trial court did not err.Defendant was found guilty of possession of cocaine with intent to deliver and possession of marijuana with intent to deliver. Defendant's sentences were enhanced under Ark. Code Ann. 5-64-408 for a subsequent controlled-substance conviction. Defendant was sentenced to 840 months' and 240 months' imprisonment, to be served consecutively. The court of appeals affirmed. In his petition to correct an illegal sentence, Defendant argued that the sentences imposed exceeded the statutory maximum for the offenses for which he was convicted. The trial court denied relief. The Supreme Court affirmed, holding that Defendant's sentences were legally enhanced under section 5-64-408(b), and Defendant did not establish that his sentences were facially illegal. View "Darrough 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 pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law.Appellant was convicted of capital murder and sentenced to life imprisonment without parole. Appellant later filed a petition for writ of habeas corpus alleging that the judgment was void because the felony information was signed by a deputy prosecutor rather than the prosecutor. The circuit court denied the petition without a hearing. The Supreme Court affirmed, holding that Appellant's challenge to the validity of the felony information did not establish a ground for the writ. View "Randle v. Straughn" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Father's petition to modify a joint custody order and give him primary custody of his minor daughter and denying Mother's petition for attorney fees, holding that the circuit court did not err.In the parties' divorce decree, the circuit court ordered joint custody of the child with each parent to have physical custody of the child on alternating weeks. Father later the petition for change of custody that was at issue in this appeal. The circuit court found a material change of circumstances but concluded that the best interest of the child required it to maintain the status quo. The Supreme Court affirmed, holding (1) there was no clear error in the circuit court's decision to maintain the joint-custody arrangement; and (2) the circuit court did not abuse its discretion in not awarding Mother attorney's fees. View "Pace v. Pace" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to allow him to file a petition for writ of error coram nobis in his criminal case, holding that Petitioner did not meet his burden of establishing that he was entitled to coram nobis relief.In his petition, Petitioner asserted that the State withheld material evidence from the defense in violation of Brady v. Maryland, 373 U.S. 83 (1963), by not turning over exculpatory evidence concerning DNA testing and a firearm that was not adequately tested by the State for fingerprints. The Supreme Court denied the petition, holding (1) the fact that certain scientific testing was not performed on an item in evidence did not constitute a showing that the testing was hidden by the State; and (2) Petitioner's remaining allegation was not within the purview of the writ. View "McKinney v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding that Defendant had the capacity to knowingly and intelligently waive his postconviction remedies, including his Ark. R. Crim. P. 37.5 petition, was not clearly erroneous and affirmed the circuit court's dismissal of Defendant's Rule 37.5 petition, holding that the court did not err.Defendant was convicted was capital murder and other crimes. Defendant later filed for postconviction relief pursuant to Ark. R. Crim. P. 37.5, arguing that counsel was constitutionally ineffective for failing to investigate sufficiently whether he was intellectually disabled. Counsel subsequently advised the circuit court that Defendant desired to waive his postconviction remedies, including his Rule 37.5 petition, which counsel asked the court to dismiss. After a hearing to determine whether Defendant had the capacity to waive his postconviction remedies, the circuit court concluded that Defendant's waiver was made knowingly and intelligently. The Supreme Court affirmed, holding that the circuit court did not err in dismissing Defendant's Rule 37.5 petition. View "Lard v. State" on Justia Law

The Supreme Court reversed the circuit court's decision granting summary judgment for Dr. Martin T. Faitak and dismissing J. David John's complaint alleging claims of medical negligence and other torts, holding that Faitak was not entitled to quasi-judicial immunity in this case.John's claims concerned psychological and counseling treatment Faitak provided to John and Megan Bolinder, who were parties in a custody case involving John and Megan's child. The circuit court concluded that Faitak was entitled to quasi-judicial immunity. The Supreme Court reversed, holding that quasi-judicial immunity did not apply to the alleged acts upon which John's claims were based. View "John v. Faitak" on Justia Law

The Supreme Court denied Petitioner's fourth pro se petition to reinvest jurisdiction in the circuit court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate a fundamental error of fact that was extrinsic to the record that would warrant issuance of the writ.In his fourth coram nobis petition, Petitioner asserted his innocence and alleged that his trial was defective due to fraudulent testimony against him. Petitioner also challenged the sufficiency of the evidence and other asserted errors. The Supreme Court denied relief, holding that Petitioner was not entitled to coram nobis relief. View "Burks v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions and sentence and granted Defendant's counsel's motion to withdraw, holding that no error occurred in the proceedings and that there were no nonfrivolous issues that supported an appeal in this case.Defendant was convicted of first-degree murder with a firearm and sentenced to life imprisonment. Defendant's counsel filed a motion to withdraw as counsel and a no-merit brief stating that there were no meritorious grounds to support an appeal. The Supreme Court affirmed Defendant's convictions and granted counsel's motion to withdraw, holding (1) Defendant's appellate counsel demonstrated that any appeal would be frivolous and that this appeal had no merit; and (2) no prejudicial error occurred in the proceedings below. View "Riley v. State" on Justia Law