Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court reversed the order of the circuit court denying the motion filed by the Arkansas Department of Human Services (DHS) to dismiss Plaintiffs' amended complaint alleging violations of the Arkansas Civil Rights Act, holding that sovereign immunity barred Plaintiffs' claims.In their complaint, Plaintiffs alleged, individually and on behalf of their three minor children, that the entrance of a DHS investigator and law enforcement into their children's private school for the purpose of investigating possible child maltreatment was illegal and unconstitutional. DHS filed a motion to dismiss, asserting sovereign immunity and other defenses. The circuit court denied the motion to dismiss. The Supreme Court reversed, holding that the circuit court erred in denying DHS's motion to dismiss based on sovereign immunity. View "Arkansas Department of Human Services v. Harris" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to file a petition for writ of error coram nobis and audita querela in his criminal case, holding that Petitioner's claims did not establish a ground for the writ.In his petition, Petitioner argued that the trial court erred in failing to apply the criminal code section that was in effect at the time was committed and that the prosecutor committed a Brady violation by withholding a medical report pertaining to an examination of the victim. The Supreme Court denied relief, holding that the existence of medical records that described the absence of corroborating physical evidence was known to defense counsel and that, even if the prosecutor had withheld this medical report, the outcome of the trial would not have changed as a result. View "Tolston v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1, in which he would challenge a judgment reflecting his sentence of life imprisonment without parole for capital murder, holding that Petitioner failed to set out a meritorious basis for relief under Rule 37.1.The judgment challenged by Petitioner was entered in 1978. In his petition, Petitioner alleged seven bases for grounds for Rule 37 relief, all framed as claims of ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner failed to set forth meritorious grounds for postconviction relief under the Rule that may be included in the proposed petition. Therefore, the Court held, there was no need to reinvest jurisdiction in the trial court. View "Hallman v. State" on Justia Law

The Supreme Court affirmed the circuit court's dismissal of Plaintiff's complaint filed against Arkansas prison officials under the Arkansas Civil Rights Act and state tort law for allegedly depriving him of a nutritionally adequate diet safe for consumption but reversed the circuit court's imposition of a strike for the dismissal of the underlying action, holding that dismissal was warranted but the strike was not.In dismissing the complaint, the circuit court concluded that Plaintiff's claims were barred by sovereign and statutory immunity and failed to state facts upon which relief could be granted. The court also issued a strike under Ark. Code Ann. 16-68-607. The Supreme Court affirmed in part and reversed in part, holding (1) because Plaintiff's allegations failed to establish a constitutional violation Plaintiff failed to surmount sovereign and statutory immunity; and (2) the strike was unwarranted. View "Harmon v. Payne" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for a writ of error coram nobis, holding that Petitioner's claims were not cognizable in coram nobis proceedings.In his petition, Petitioner alleged that prejudicial testimony provided by the State's expert witness was admitted at trial without objection from counsel or an admonishment from the trial court and that the admission of this testimony deprived him of due process. The Supreme Court denied the petition, holding that there was no error in the admission of the allegedly prejudicial testimony, and therefore, Petitioner failed to allege a due process violation that would come within the purview of coram nobis relief. View "Henington v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the circuit court's order awarding damages under the Arkansas Civil Rights Act to Alexander Apartments, LLC and certain tenants after determining that the City of Little Rock violated Appellees' due process rights under the Arkansas Constitution, holding that the circuit court correctly found that the City violated Appellees' due process rights but incorrectly awarded damages.On appeal, the City argued that it did not violate Alexander Apartments' or the tenants' due process rights under the Arkansas Constitution. The Supreme Court disagreed, holding (1) the circuit court was correct as a matter of law that the City violated Alexander Apartments' and the tenants' due process rights under the Arkansas Constitution; (2) substantial evidence supported the circuit court's award of damages to Alexander Apartments in the amount of $432,744.33; and (3) the circuit court erroneously considered events and circumstances that were unrelated to the City's due process violations in determining the tenants' damages awards. View "City of Little Rock v. Alexander Apartments, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant's petition for writ of error coram nobis, holding that Appellant did not show an abuse of discretion in the denial of the writ.In 1979, Appellant was convicted of capital felony murder. After the Supreme Court gave Appellant leave to proceed with a coram nobis petition, Appellant filed his petition, alleging a violation of Brady v. Maryland, 373 U.S. 83 (1963). The trial court determined that no Brady violation had occurred and declined to issue the writ. On appeal, Appellant claimed that the trial court failed to conduct a proper analysis when it did not treat the admission of certain evidence as structural error and failed to apply the law of the case doctrine. The Supreme Court affirmed, holding that the error in this case was not structural and that the court was correct in its analysis. View "Pitts v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the circuit court's order granting a motion to dismiss filed by the Arkansas Governor and Arkansas Livestock and Poultry Commission Deputy Director and dismissing Plaintiff's claims pursuant to the Arkansas Whistle-Blower Act, Ark. Code Ann. 21-1-601 et seq., as well as the state and federal constitutions, holding that sovereign immunity barred Plaintiff's claims against Defendants in their official capacities but was no defense to Plaintiff's claims against Defendants in their individual capacities.In his complaint, Plaintiff alleged that he was terminated because he refused to violate state policy. The circuit court dismissed all claims against Defendants solely on the basis of sovereign immunity. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) sovereign immunity precluded Plaintiff's official capacity claims; but (2) the circuit court erred when it found that sovereign immunity barred Plaintiff's claims against Defendants in their individual capacities. View "Harris v. Hutchison" on Justia Law

The Supreme Court denied Petitioner's petition seeking permission to proceed in the trial court with a petition under Ark. R. Crim. P. 37.1 in which Petitioner argued that he was entitled to collaterally attack his conviction and alternatively requesting that the Supreme Court recall the mandate for his two convictions, holding that Petitioner did not state a claim for relief.Petitioner argued that he was entitled to collaterally attack his conviction because the Arkansas statute under which his arrest warrants were issued was declared unconstitutional under Fairchild v. Lockhart, 675 F. Supp. 469 (1987). The Supreme Court held (1) Petitioner's reliance on Fairchild was unavailing, and even if Petitioner's arrest was illegal, it does not follow that his charges should be dismissed; and (2) Petitioner failed to establish any basis for the Supreme Court to recall its mandate. View "Logan v. State" on Justia Law

In this case involving the administration of several family trusts the Supreme Court reversed the denial of a jury trial on Appellant's legal claims and affirmed in all other respects the order of the circuit court denying Appellant's petition to direct trustee to issue trusts reports and accountings and for removal of trustees and for other relief, holding that the circuit court erred by denying Appellant a jury trial on his legal claims but otherwise did not err.Specifically, the Supreme Court held (1) the chief justice had jurisdiction to appoint a special judge in the case; (2) the circuit court erred by denying Appellant a jury trial on his legal claims, but Appellant was not entitled to a trial by jury on his equitable claims; (3) the circuit court did not err by relying on extrinsic evidence to determine settlor intent; (4) the circuit court did not err by denying Appellant's claim for failure to provide an accounting or in declining to appoint a special master; and (4) the circuit court did not err in not invalidating trust amendments. View "Dawson v. Stoner-Sellers" on Justia Law