Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court affirmed the circuit court's dismissal of Appellant's pro se complaint alleging constitutional violations of his right to due process and constitutional violations of the ex post facto prohibition in connection with the denial of his application for parole, holding that Appellant's sole claim on appeal was abandoned.On appeal, Appellant argued for the first time that Appellees violated his right to equal protection because he had been treated differently from similarly situated inmates. The Supreme Court affirmed the circuit court's order dismissing Appellant's complaint, holding that because Appellant did not raise the argument below the issue could not be considered by this Court. View "Boydston v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court awarding attorney's fees to Allen Hargis following the division of Allen's military retirement account after the divorce of Allen and Lynn Harris, holding that the circuit court did not abuse its discretion by failing to conduct a hearing on the parties' respective financial abilities prior to awarding attorney's fees.After resolving the parties' dispute over the division of Allen's military retirement account following their divorce the circuit court awarded attorney's fees to Allen. On appeal, Lynn argued that the circuit court's failure to conduct a hearing prior to awarding attorney's fees infringed on her right to procedural due process under the Fourteenth Amendment. The Supreme Court affirmed, holding that the circuit court was not obligated to conduct an evidentiary hearing under the Fourteenth Amendment and that Lynn was not denied an opportunity to be heard on Allen's motion for attorney's fees. View "Hargis v. Hargis" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the circuit court's denial of his petition for writ of habeas corpus, holding that because Appellant was no longer incarcerated, the circuit court could not grant him the relief he requested.In his habeas petition, Petitioner challenged two judgments entered in 2008 and 2011. When he filed his habeas petition Petitioner was incarcerated in an Arkansas Department of Correction facility. By the time this case reached the Supreme Court Appellant was no longer incarcerated by the Arkansas Department of Correction. The Supreme Court dismissed Appellant's appeal from the denial of his petition, holding that the circuit court lacked jurisdiction to grant the requested relief. View "Green v. Kelley" on Justia Law

Posted in: Criminal Law
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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 demonstrating a fundamental error of fact extrinsic to the record that was concealed from the defense and that was both material and prejudicial such as to have prevented rendition of the judgment had it been known at the time of trial.In his petition, Petitioner argued that the State withheld material evidence from the defense by failing to comply with pretrial discovery. The Supreme Court denied the petition, holding that Petitioner's conclusory allegations failed to demonstrate that the State concealed evidence or that Petitioner suffered prejudice sufficient to establish that a violation of Brady v. Maryland, 373 U.S. 83 (1963), occurred. View "Breeden v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court denying Appellant's pro se petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the circuit court abused its discretion in declining to issue the writ.Appellant pleaded guilty to second-degree murder and was sentenced to 240 months' imprisonment, in addition to 120 months' imprisonment, suspended. Appellant later filed a pro se petition for writ of error coram nobis, alleging a coerced guilty plea, fraud or mistake, and withheld evidence. The circuit court denied the writ. The Supreme Court affirmed, holding that the coram nobis petition had no merit. View "Pugh v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court denying motions to compel arbitration of a class-action complaint filed by Appellees, holding that Appellants failed to meet their burden of proving a valid and enforceable arbitration agreement with respect to certain agreements but that Appellants met their burden to prove the validity of the remainder of the arbitration agreements.Appellees filed a class-action complaint against Appellants, a nursing home and related entities, alleging that Appellants had breached their admission and provider agreements, violated the Arkansas Deceptive Trade Practices Act, committed negligence and civil conspiracy, and had been unjustly enriched. Appellants' filed four motions to compel arbitration with respect to ten class members/residents. The circuit court denied the motions. The Supreme Court affirmed in part and reversed in part, holding (1) certain arbitration agreements contained deficiencies that prevented Appellants from meeting their burden of proving a valid and enforceable arbitration agreement; and (2) Appellants met their burden to prove the validity of the remainder of the arbitration agreements not already discussed. View "Robinson Nursing & Rehabilitation Center, LLC v. Phillips" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first degree murder, attempted first-degree murder, and a firearm enhancement, holding that the circuit court did not err in denying Defendant's motion for a mistrial.On appeal, Defendant argued that his constitutional rights were violated during his cross-examination of a witness when that witness testified regarding Defendant's right to remain silent.The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in overruling the objection to the testimony because the comment was not the type of comment prohibited by the United States Supreme Court in Doyle v. Ohio, 426 U.S. 610, 618 (1976). View "Sirkaneo v. State" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court dismissing Appellant's habeas corpus petition and denying his motion for reconsideration, holding that the petition was untimely and failed to rebut the presumption of untimeliness.Appellant's habeas corpus petition alleged his actual innocence and sought new DNA testing under Ark. Code Ann. 16-112-103 to -123 and Act 1780 of 2001 Acts of Arkansas. The circuit court dismissed the petition based on jurisdiction. The Supreme Court affirmed but on different grounds, holding (1) the circuit court had jurisdiction to consider Appellant's petition for new scientific testing under Act 1780; but (2) the petition was untimely, and therefore, the circuit court was not clearly erroneous in dismissing Appellant's petition. View "Gipson v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the circuit court denying Petitioner's petition for postconviction relief alleging ineffective assistance of trial and appellate counsel, holding that Petitioner's allegations were unavailing.Petitioner was convicted of first-degree felony murder, aggravated robbery, felony theft, and misdemeanor theft. The Supreme Court reversed the aggravated robbery convictions and remanded for resentencing. After resentencing, Petitioner petitioned for postconviction relief under Ark. R. Civ. P. 37, alleging that he received constitutionally deficient counsel both at trial and on direct appeal. The Supreme Court affirmed, holding that the circuit court did not err in rejecting Petitioner's alleged errors with respect to trial counsel's performance and that Petitioner's claims of ineffective assistance of appellate counsel were without merit. View "Thompson v. State" on Justia Law

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The Supreme Court denied Petitioner's motion to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner did not timely file his petition and otherwise failed to state sufficient facts establishing his entitlement to the writ.Petitioner was convicted of first-degree murder and aggravated robbery. In his coram nobis petition, Petitioner alleged that a third party confessed to the crime during the time between conviction and appeal. Petitioner subsequently filed a motion for leave to file a reply to the State's response to his petition. The Supreme Court denied both the petition and the motion, holding that the petition was untimely, and the rules do not permit a reply to a response to a coram nobis petition. View "Thornton v. State" on Justia Law

Posted in: Criminal Law