Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court resentencing Defendant to life imprisonment after his original life-without-parole sentence was vacated due to Miller v. Alabama, 567 U.S. 460 (2012), holding that the circuit court erred by allowing the jury to be informed of Defendant's prior sentence.Defendant pleaded guilty to capital murder and attempted capital murder and was sentenced to life without the possibility of parole. After Miller was decided, the Supreme Court granted habeas relief and remanded to the circuit court for a sentencing hearing where Defendant could present Miller evidence for consideration. The circuit court held a resentencing trial, and the jury sentenced Defendant to life. On appeal, Defendant argued that the circuit court erred by permitting the jury to be informed that Defendant was previously sentenced to life imprisonment without parole. The Supreme Court reversed and remanded the case for a new sentencing trial, holding that the circuit court abused its discretion in not excluding this evidence pursuant to Ark. R. Crim. P. 403 and that the error was not harmless. View "Kitchell v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree murder and sentence of life imprisonment, holding that the circuit court did not err in the proceedings below.Specifically, the Court held that the circuit court (1) did not err in denying Defendant's motions for directed verdict; (2) did not err in denying Defendant's motion to suppress his custodial statement; (3) did not err in denying Defendant's motion for mistrial based on a prejudicial outburst from the witness stand; and (4) did not err in excluding the testimony of a witness that Defendant alleged would have pointed to someone else as the killer. View "Halliburton v. State" on Justia Law

In this insurance dispute, the Supreme Court reversed the orders and judgment of the circuit court in favor of Edna Lyle Lovelace, holding that the circuit court erred in determining that Shelter Mutual Insurance Company's policy language excluding coverage for an intentional act, as applied to an innocent co-insured, is void against public policy.Shelter Mutual determined that Lovelace's husband, Frank Williams, caused the fire that destroyed Lovelace's home and its contents. Williams did by suicide inside the home and left a suicide note before the fire started. Shelter Mutual denied coverage to Lovelace in accordance with an exclusion precluding coverage for an intentional act. Lovelace brought this action, arguing that the policy language allowing Shelter Mutual to deny a claim by an innocent insured because of actions taken by another insured was void as against public policy. The circuit court ruled that the exclusion was void as against public policy and entered judgment against Shelter Mutual. The Supreme Court reversed, holding that the intentional-act exclusion as applied to an innocent co-insured was not void as against public policy. View "Shelter Mutual Insurance Co. v. Lovelace" on Justia Law

The Supreme Court reversed the order of the circuit court denying the City of Fort Smith's motion to compel class notice on Plaintiff's claims alleging illegal exaction and unjust enrichment against on the ground that the City waived notice by moving for summary judgment prior to class certification and notice, holding that the circuit court erroneously interpreted National Enterprises, Inc. v. Kessler, 213 S.W.3d 597 (Ark. 2005).Plaintiff alleged that the City misused public funds from the City's curbside residential recycling program. Twelve days after her complaint was filed Plaintiff moved for class certification. The City responded to the class certification motion and, separately, moved for summary judgment. The circuit court then certified the same class for both claims and, three months later, denied the City's motion for summary judgment. The City later filed its motion to compel class notice. The circuit court held that, under Kessler, the timing of the City's motion for summary judgment waived notice even though the motion was ultimately successful. The Supreme Court reversed, holding that the circuit court's decision was premised on an erroneous interpretation of the Supreme Court's decision in Kessler. View "City of Fort Smith v. Merriott" on Justia Law

The Supreme Court affirmed the judgment of the circuit court rejecting Appellant's proffered jury instructions at his resentencing hearing, holding that the circuit court did not abuse its discretion.At age seventeen, Appellant committed capital murder and rape. Appellant received a mandatory sentence of life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant's life sentence for capital murder was vacated. After a resentencing hearing a jury sentenced Appellant to life imprisonment. On appeal, Appellant argued that the circuit court erred in rejecting his proffered jury instructions on capital murder. The Supreme Court affirmed, holding that because Appellant's proffered instructions would ask the jury to make findings required only in death cases the circuit court properly refused to give those instructions. View "Hundley v. State" on Justia Law

The Supreme Court affirmed the circuit court's order denying Appellant's petition for a writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant did not state a ground for the writ.Appellant pled guilty to four counts of first-degree sexual assault. At the time of the trial court proceedings, Appellant requested a mental evaluation. After the circuit court granted the request Appellant withdrew the request and pled guilty. Thereafter, the forensic evaluation was submitted to the court with a finding that Appellant was competent and fit to proceed. In his habeas corpus petition, Appellant argued that the circuit court lacked subject matter jurisdiction to accept his guilty plea before the mental evaluation was filed. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was one that fell within the scope of habeas, but Appellant's claim that the circuit court was divested of jurisdiction due to the lack of a forensic report at that time of the proceeding failed. View "Hayes v. Kelley" on Justia Law

The Supreme Court denied Appellant's petition for rehearing of the Court's decision affirming the circuit court's denial of Appellant's petition for postconviction DNA testing under Act 1780, holding that Appellant's petition for rehearing failed to comport with the requirements set forth in Arkansas Supreme Court Rule 2-3(g).On appeal from the denial of his postconviction motion, the Supreme Court affirmed the conclusion of the circuit court that the proposed scientific testing under Act 1780 could not raise a reasonable probability that Defendant did not commit the murder for which he was convicted and that the admissibility of proffered eyewitness identification testimony was procedurally barred from consideration. In his petition for rehearing, Appellant reiterated the same arguments that were considered and rejected on appeal and, for the first time, asserted a constitutional claim. The Supreme Court denied the petition for rehearing, holding that the entirety of the petition fell outside the scope of rehearing under Rule 2-3(g). View "Johnson v. State" on Justia Law

The Supreme Court affirmed the orders of the circuit court denying Appellant's two pro se petitions challenging his 1993 conviction for first-degree murder and sentence of life imprisonment, holding that the circuit court properly denied relief.The first petition Appellant filed sought scientific testing for habeas relief under Act 1780 of 2001 Acts of Arkansas, codified at Ark. Code Ann. 16-112-201 to -208. The second petition sought relief from an illegal sentence. The circuit court denied both petitions. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief under Act 1780; and (2) Appellant failed to allege facts that would support his claim of an illegal sentence. View "Mcarty 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 pled nolo contendere to two counts of second-degree sexual assault. Appellant later filed the petition for writ of habeas corpus alleging claims of actual innocence and insufficient evidence. The circuit court denied the dismissed the petition. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of demonstrating that he was being illegally detained and entitled to issuance of a writ of habeas corpus to effect his release from custody; and (2) Appellant offered no well-founded argument for the Court to expand the writ. View "Young v. Kelley" on Justia Law

The Supreme Court affirmed the order of the circuit court granting Appellant a divorce, dividing the parties' marital property, and awarding alimony to Appellee, holding that the circuit court's rulings were not clearly erroneous.The parties in this case entered into an arranged marriage in India. Approximately one year later, Appellant filed a complaint for divorce. After the divorce decree was entered Appellant appealed. The Supreme Court affirmed, holding that the circuit court (1) did not err by equally dividing the funds that Appellant spent during the parties' separation; (2) did not err in deciding to divide equally the marital assets; and (3) did not err by awarding Appellee rehabilitative alimony. View "Chekuri v. Nekkalapudi" on Justia Law