Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Petitioner's petition for coram nobis relief, holding that Petitioner failed to establish that the trial court abused its discretion and that the writ should have issued.Appellant pleaded guilty to first-degree battery and other offenses. Ten years later, Appellant filed a second pro se petition for writ of error coram nobis challenging the judgment. The trial court denied relief. The Supreme Court reversed and remanded, concluding that Appellant's Brady claim may have merit and that the trial court should hold an evidentiary hearing to consider the merits of the petition. On remand, after an evidentiary hearing, the trial court again denied relief. Appellant appealed, raising six claims of error. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in denying the writ for coram nobis relief. View "Scott v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of capital murder, aggravated robbery, and a firearm enhancement, holding that there was no prejudicial error in the proceedings below.On appeal, Defendant argued that the circuit court erred in denying his motion to suppress his statements to police recorded in a police interrogation room and an alleged nonrecorded custodial statement made while police escorted him to a police car. The Supreme Court affirmed, holding (1) the circuit court did not clearly err in rejecting Defendant's argument that the issuance of Miranda warnings was rendered ineffective; and (2) Defendant's remaining allegations of error were without merit. View "Pree v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of rape of a minor and sentence of life imprisonment without parole, holding that the circuit court did not err in denying Defendant's motions to dismiss and did not abuse its discretion in admitting certain evidence.Specifically, the Court held that the circuit court (1) did not err in denying Defendant's motion to dismiss for violating Defendant's right to a speedy trial because Defendant's speedy trial rights were not violated; (2) did not err in denying Defendant's motion to dismiss for prosecutorial delay because Defendant was not prejudiced by the delay of filing the charges; and (3) did not abuse its discretion in admitting an Arkansas Department of Correction "pen pack" and an Arkansas Court of Appeals opinion as evidence of prior convictions. View "Rayburn v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder in the first degree, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held that the trial court (1) did not err by denying Defendant's motion for directed verdict because there was sufficient evidence that Defendant acted with the purpose of causing the death of the victim; (2) did not abuse its discretion in allowing testimony over Defendant's objection involving prior incidents unrelated to the night of the charged murder; and (3) did not err in refusing Defendant's motion for a jury instruction on justification for manslaughter because the jury never considered manslaughter. View "Coakley v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of capital murder and first-degree battery, holding that the circuit court did not abuse its discretion in denying Defendant's motion for mistrial.On appeal, Defendant argued that a mistrial was warranted on the basis of a witness's statements during cross-examination. During trial, the witness accused defense counsel of threatening him and making other statements suggesting that defense counsel was trying to conceal evidence of Defendant's guilt. The Supreme Court affirmed, holding that the statement was not of such magnitude that it was an abuse of discretion for the circuit court to deny the motion for a mistrial, and the circuit court's admonition to the jury was sufficient to cure any possible prejudice stemming from the witness's remarks. View "Braud v. State" on Justia Law

The Supreme Court vacated the opinion of the court of appeals dismissing for lack of subject matter jurisdiction the appeal from a dependency-neglect case in which the circuit court entered an order awarding permanent custody, holding that the appeal was timely filed. The circuit court entered an order awarding permanent custody of four minor children to the children's foster parents and closed the dependency-neglect case that the Arkansas Department of Human Services had brought against the children's parents. After the four minor children unsuccessfully filed a motion for relief from judgment they filed a notice of appeal. The court of appeals dismissed the matter for lack of jurisdiction. The Supreme Court vacated the court of appeals' opinion and remanded the case for further action, holding that the appeal from the order awarding permanent custody was timely filed. View "Minor Children v. Arkansas Department of Human Services" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder in the first degree and battery in the first degree, holding that the circuit court did not err when it denied Appellant's request to instruct the jury as to the lesser-included offenses of murder in the second degree, extreme emotional distress manslaughter, and battery in the second degree.Specifically, the Court held (1) the circuit court did not abuse its discretion by refusing to give Appellant's proffered second-degree murder instruction because there was no rational basis for doing so; (2) the court did not abuse its discretion by deciding not to give the extreme emotional disturbance manslaughter instruction; and (3) the circuit court did not err when it refused to instruct the jury as to second-degree battery. View "Dixon v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree battery and possession of a firearm by certain persons but remanded with instructions to correct the sentencing order, holding that the circuit court did not abuse its discretion by limiting Defendant's cross-examination of the victim.Specifically, the Court held (1) the circuit court did not err in not allowing Defendant to ask six questions during the victim's cross-examination because Defendant failed to proffer the answers that he hoped to elicit on cross-examination and because the answers were not otherwise apparent from the contradictory context; (2) the circuit court did not err in denying Defendant's motion to dismiss for lack of a speedy trial; and (3) because the sentencing order misidentified an offense, the matter must be remanded for the court to correct the sentencing order. View "Perkins v. State" on Justia Law

The Supreme Court affirmed the decision of the circuit court granting an improvement district's (District 84) request for foreclosure and entering judgment against TND Developers, LLC for the total of unpaid improvement district taxes and ordering all TND lands within the district sold with the proceeds applied against the improvement district's judgment, holding that Appellants' claims on appeal failed.On appeal, Appellants argued, inter alia, that District 84's lien for nonpayment of improvement taxes could only attach to individual tracts upon which taxes were actually delinquent and unpaid, and therefore, an in rem judgment could not be attached to certain tracts. The Supreme Court affirmed, holding (1) Ark. Code Ann. 14-94-118 makes clear that all unreleased property within the district is subject to District 84's tax lien; (2) because District 84's complaint plainly described the land it sought to foreclose, as well as the tracts excluded from the action, the circuit court did not err in allowing District 84 to proceed on the basis of a statutorily defective complaint; (3) District 84 did not improperly refuse prepayment of improvement taxes; (4) Appellants' claims for equitable estoppel or equitable subordination failed; and (5) the circuit court's order did not violate Appellants' due process rights. View "Bullock's Kentucky Fried Chicken, Inc. v. City of Bryant, Arkansas" on Justia Law

The Supreme Court affirmed the decision of the Arkansas Department of Correction (ADC) denying Appellant's petition to proceed in forma pauperis in a civil action requesting judicial review, holding that Appellant failed sufficiently to raise a constitutional question.In his civil action, Appellant asserted that prison officials initiated and conducted disciplinary proceedings against him in violation of his constitutional rights. The circuit court concluded that Appellant failed to state a colorable cause of action and that ADC officials were entitled to sovereign immunity. The Supreme Court affirmed the circuit court's denial of Appellant's petition, holding that Appellant did not state sufficient allegations entitling him to judicial review of ADC's administrative procedures. View "Muntaqim v. Kelley" on Justia Law