Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the circuit court finding attorney Jonathan Streit in contempt of court and assessing a $100 fine, holding that substantial evidence supported the court's decision that Streit's actions displayed a lack of regard for the court's integrity and demonstrated disrespect.Streit appeared before the circuit court on a petition for permanent guardianship. At the hearing, the circuit court noted several deficiencies in the case file. The circuit court was unwilling to let the matter to proceed without compliance with the statutory requirements, and Streit argued that the circuit court took issue with him because he successfully reversed the circuit court in a separate case. The circuit court then found Streit in contempt of court and assessed a fine. The Supreme Court affirmed, holding that substantial evidence supported the court's decision to hold Streit in contempt. View "Streit v. State" on Justia Law

The Supreme Court dismissed as moot a direct appeal challenging the circuit court's order declaring the Arkansas State Plant Board's dicamba cutoff rule as void and dismissed in part and reversed in part the cross appeal challenging the same order dismissing with prejudice certain farmers' complaint on the basis of the Board's sovereign immunity, holding that the Farmers' constitutional claims were not subject to the sovereign immunity defense.In 2017, the Board voted to ban the in-crop use of dicamba-based herbicides after April 15, 2018. The Farmers sought declaratory and injunctive relief alleging that the process by which Board members were appointed was unconstitutional. Thereafter, the new rule took effect, and the Board filed a motion to dismiss the Farmers' complaint. The circuit court granted the Board's motion to dismiss on the basis of sovereign immunity. However, the court determined that the Board's sovereign immunity violated the Farmers' due process rights, thus holding that the Board's rule was void ab initio and null and void as to the Farmers. The Supreme Court held (1) the Board's appeal was of the portion of the circuit court's order declaring the Board's rule establishing the cutoff date for the application of dicamba herbicides was moot; but (2) the Farmers' constitutional claims could proceed. View "Arkansas State Plant Board v. McCarty" on Justia Law

The Supreme Court denied Petitioner's motion for permission to proceed with a belated appeal of an order denying his pro se petition for writ of error coram nobis, which mooted his additional motions, holding that the circuit court did not abuse its discretion in denying relief.In addition to his motion for belated appeal Petitioner filed motions for appointment of counsel, to supplement appeal, to file rule on clerk, to add "to [his] error coram nobis," second motion to supplement, and second motion to add. In his coram nobis petition Petitioner asserted that his allegations of mental disease or defect were not fully adjudicated, that his guilty plea was coerced, and that his trial counsel was ineffective. The circuit court denied the petition. The Supreme Court held that Petitioner's ineffective assistance of counsel claim was not a ground for the writ and that the two other claims failed to allege any facts to support those claims. Therefore, the Court held, the coram nobis petition was wholly without merit, and Petitioner could show no abuse of discretion in the denial of relief and could not prevail on appeal. View "Bryant v. State" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's petition for habeas relief, holding that the circuit court did not clearly err when it denied the petition.As grounds for his petition, Appellant argued that his arrest was invalid because an arrest warrant did not issue, the criminal information was filed without supporting documentation, and the introduction of any evidence was illegal according to the fruit of the poisonous tree doctrine. The circuit court denied relief. The Supreme Court affirmed, holding that Appellant failed to demonstrate error in the dismissal of his petition because he failed to allege a basis for the circuit court to grant the writ. View "Mister v. Kelley" on Justia Law

The Supreme Court mooted in part and reversed and remanded in part the decision of the circuit court dismissing Monsanto Company's amended complaint against the Arkansas State Plant Board and its members (collectively, the Plant Board) on the basis of sovereign immunity, holding that portions of this matter were moot and, as to the remainder, sovereign immunity was inapplicable.In 2017, the Plant Board promulgated a rule that would prohibit in-crop use of dicamba herbicides during the 2018 growing season. Monsanto filed a complaint setting forth seven alleged claims against the Plant Board. Each of Monsanto's claims sought injunctive or declaratory relief for alleged illegal or unconstitutional activity by the Plant Board and did not seek an award of monetary damages in any respect. The circuit court granted the Plant Board's motion to dismiss based on sovereign immunity. The Supreme Court reversed, holding (1) the portions of the complaint that relate exclusively to the 2016 and 2017 promulgations were moot because the Plant Board has since promulgated a new set of regulations on pesticide use; and (2) Monsanto's claims were sufficiently developed as to properly allege ultra vires conduct, and under the circumstances, the Plant Board must address the merits of Monsanto's claims. View "Montsanto Co. v. Arkansas State Plant Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's motion for preliminary injunction, holding that the circuit court correctly concluded that Appellant failed to demonstrate a likelihood of success on the merits.Appellant was an inmate of the Arkansas Department of Correction (ADC) and a professed member of the Nation of Islam (NOI). Appellant filed the underlying suit against numerous ADC officials, alleging violations of the First Amendment and the federal Religious Land Use and Institutionalized Persons Act. Appellant moved for a preliminary junction against ADC's publications policy as applied to NOI material and against ADC's religious services policy so that he may lead NOI services in prison. The circuit court denied Appellant's motion for preliminary injunction, determining that Appellant failed to show irreparable harm and failed to demonstrate a likelihood of success on the merits. The Supreme Court affirmed, holding that the circuit court did not exceed its discretion in deciding not to issue a preliminary injunction. View "Muntaqim v. Lay" on Justia Law

The Supreme Court affirmed the order of the circuit court denying Appellant leave to proceed in forma pauperis on his petition for writ of habeas corpus, holding that the underlying habeas petition set out a claim that fell within those cognizable for the writ, yet it did not provide an adequate demonstration of probable cause to support issuance of the writ.Appellant was convicted of rape and first-degree sexual assault entered on a negotiated guilty plea and was sentenced to sixty years' imprisonment. Appellant filed a petition for writ of habeas corpus alleging that the trial court did not have the authority to enter the judgment because he did not in fact enter a guilty plea. Appellant then filed his petition for leave to proceed in forma pauperis. The circuit court denied relief, finding sufficient evidence that Appellant was indigent but that he failed to allege a matter cognizable in a petition for the writ. The Supreme Court affirmed, holding that the claims in Appellant's habeas petition were not sufficient to support his allegations of a colorable cause of action. View "Morgan v. Kelley" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying the motion to dismiss filed by Jimmy Banks, Warden of the Varner Unit of the Arkansas Department of Correction (ADC), as to Sharon Jones's complaint alleging that she had been terminated from her employment at the Varner Unit due to racial and gender discrimination, holding that Jones failed to state factual allegations that alleged a deprivation of any constitutional right.In her complaint, Jones, an African American woman, alleged that she was subjected to unlawful racial and gender discrimination because she was discharged under circumstances that similarly situated white or male employees were not. Banks filed a motion to dismiss based on constitutional sovereign immunity, qualified immunity, and statutory immunity. The circuit court denied the motion. The Supreme Court reversed, holding that Banks was entitled to qualified immunity under Jones's 42 U.S.C. 1983 claims and statutory immunity against her state law claims. View "Banks v. Jones" on Justia Law

The Supreme Court affirmed the decision of the circuit court denying Appellant's request to proceed in forma paupers on a petition for writ of habeas corpus, holding that Appellant failed to state a colorable cause of action for habeas relief.Appellant was convicted of drug-related crimes. Appellant was later convicted of additional felony offenses and sentenced as a habitual offender to life imprisonment. In the instant habeas petition, Appellant raised the same claims and factual allegations for habeas relief that he had raised previously in a habeas petition and that were rejected by this Court. The circuit court concluded that Appellant failed to state a colorable claim for habeas relief because the same claims had been previously addressed and found to be outside the purview of habeas proceedings. The Supreme Court affirmed, holding that the circuit court did not err. View "Watts v. Kelley" on Justia Law

The Supreme Court dismissed Appellant's appeal from the circuit court's denial of his pro se petition to correct an illegal sentence, which mooted Appellant's motion for an extension of time to file his brief-in-chief, holding that that Appellant's sentence of life imprisonment was illegal.Appellant was convicted of capital murder and aggravated robbery and was sentenced to life imprisonment. In his petition to correct an illegal sentence Appellant alleged that his mandatory sentence of life imprisonment should be set aside pursuant to Miller v. Alabama, 567 U.S. 460, and Graham v. Florida, 560 U.S. 48 (2010), because he was eighteen when he committed the crimes. The circuit court denied relief. The Supreme Court dismissed the appeal, which rendered Appellant's motion moot, holding that because Appellant was an adult when he committed capital murder, his sentence of life imprisonment was not illegal. View "Burgie v. State" on Justia Law