Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the trial court denying Appellant's pro se petition for postconviction relief pursuant to Ark. R. Crim. P. 37.1, holding that it was clear from the face of the petition that Appellant did not substantiate with facts a ground for relief in his Rule 37.1 petition.In his petition, Appellant alleged four of his claims of ineffective assistance of counsel. The trial court denied the petition. Appellant appealed and filed a motion for an extension of time to file a reply brief in the appeal. The Supreme Court (1) affirmed the denial of Appellant's postconviction petition, holding that Appellant failed to support the four allegations that he argued on appeal were wrongfully decided by the trial court with facts to demonstrate that he suffered actual prejudice by any of counsel's alleged errors; and (2) denied the motion for extension of brief time, holding that there was no good cause to delay action on the appeal by granting leave to file a reply brief. View "Maiden v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition for a writ of error coram nobis, which mooted Appellant's motion to file a belated brief-in-chief, holding that it was clear from the record that Appellant's allegations failed state a claim for coram nobis relief.In his petition, Appellant asserted that his guilty plea was not voluntarily or intelligently entered because his counsel led him to believe that his sentence would be life imprisonment, not life imprisonment without the possibility of parole. The Supreme Court dismissed the appeal, holding that Appellant did not allege that his guilty plea resulted from any form of physical or psychological duress as required for a writ of error coram nobis in this context. View "Wade v. State" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by the Arkansas State Highway Commission and the Arkansas Department of Transportation and its director in this challenge to a contract entered into between the Department and the United States Fish and Wildlife Service (USFWS), holding that the circuit court correctly found that the complaint failed to state facts upon which relief could be granted.Under the contract in this case the Department would cede certain property to USFWS in exchange for a fifty-acre easement over land in the Cache River and White River Wildlife Refuges in order to build a new bridge on Highway 79. The agreement further required the Department to convey additional land to USFWS and to demolish three bridges. Appellants filed a motion for preliminary injunction and complaint for declaratory and injunctive relief, arguing that the contract was unconscionable, entered into under duress, and constituted a windfall to USFWS. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that the complaint lacked sufficient facts to state a claim for an illegal exaction. View "Prince v. Arkansas State Highway Commission" on Justia Law

The Supreme Court dismissed as moot the appeal brought by Appellants, the Arkansas State Plant Board and its director, challenging the circuit court's temporary restraining order (TRO) that enjoined the Plant Board from enforcing its agency rule limiting the use of dicamba herbicides after April 15, 2018, holding that because Appellants had since repealed and replaced this rule, the appeal was moot.While Appellants' appeal was pending, the Plant Board repealed and replaced the rule. The Supreme Court held that because the judgment on this appeal would have no practical legal effect on the TRO's enforceability, this interlocutory appeal is dismissed as moot. View "Arkansas State Plant Board v. Stephens" on Justia Law

In this companion case to Arkansas State Plant Board v. Bell, __ S.W.3d __, which the Court handed down on May 23, 2019, the Supreme Court dismissed the appeal from the circuit court's temporary restraining order (TRO) that enjoined the Arkansas State Plant Board and its officers and members (collectively, the Plant Board) from enforcing its agency rule limiting the use of dicamba herbicides after April 15, 2018, holding that because the Plant Board had since repealed and replaced the rule and the TRO had expired by operation of law, the appeal was moot. View "Arkansas State Plant Board v. Johnson" on Justia Law

The Supreme Court denied Petitioner's petition seeking to reinvest jurisdiction in the trial court to consider his petition for writ of error coram nobis and to recall the Court's mandate affirming his conviction for capital murder and sentence of life imprisonment without parole, holding that Petitioner set out no basis that would support issuance of the writ or a recall of the mandate.As grounds for his petition, Petitioner alleged that the prosecutor made improper statements during his criminal trial. In an amendment to the petition, Petitioner argued that his sentence was illegal because he was eighteen years old when he committed the murder. The Supreme Court denied the petition and the amendment, holding that Petitioner failed to establish an error of fact extrinsic to the record that could not have been raised in the trial court and failed to allege any extraordinary circumstances warranting recall of the mandate. View "Muhammad v. State" on Justia Law

The Supreme Court dismissed the appeal brought by Appellant from the denial of his petition for writ of habeas corpus in which he challenged a judgment and commitment order reflecting his conviction for first-degree murder and life sentence, holding that it was clear that Appellant could not prevail on appeal.Appellant filed his petition for writ of habeas corpus in the circuit court of the county where he was incarcerated, alleging that the judgment and commitment order was facially invalid. The circuit court denied the petition. Before Appellant filed his notice of appeal he was transferred to an Arkansas Department of Correction facility in another county. The Supreme Court dismissed the appeal, holding that the circuit court did not have personal jurisdiction to issue and make returnable before itself a writ of habeas corpus to release Appellant, who was held in another county. View "Jackson v. Kelley" on Justia Law

The Supreme Court denied Petitioner's pro se second petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner's petition did not establish the prejudice prong of Brady v. Maryland, 373 U.S. 83 (1963).Petitioner was found guilty of aggravated robbery, kidnapping, and theft of property. In his coram nobis petition, Petitioner alleged that the prosecution withheld evidence with respect to agreements entered into between the prosecutor and a witness for the State, in violation of Brady v. Maryland. The Supreme Court denied relief, holding that Petitioner's claim did not satisfy the prejudice prong of Brady. View "Davis v. State" on Justia Law

The Supreme Court denied Petitioner's pro se petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram nobis, holding that Petitioner failed to demonstrate entitlement to error coram nobis relief because he failed to establish an error of fact extrinsic to the record that could not have been raised in the trial court or on direct appeal.Petitioner was convicted of capital murder that was committed in the course of an aggravated robbery. In his coram nobis petition Petitioner raised, among other things, allegations of a prejudicial jury selection process, ineffective assistance of counsel, and an unlawful arrest. Petitioner subsequently filed a motion seeking leave to file a response to the State's response, a motion for file-marked copies at public expense of his petition and other documents, and a motion for appointment of counsel. The Supreme Court denied relief, holding that the proposed claims raised by Petitioner in his petition were based on allegations that were not cognizable in coram nobis proceedings, which rendered moot two of Petitioner's motions. The Court then denied Petitioner's motion for copies at public expense of the documents filed in this pending appeal. View "Martin v. State" on Justia Law

The Supreme Court affirmed the circuit court's order granting judgment on the pleadings and dismissing Appellants' cause of action against the Kroger Company, holding that the circuit court did not abuse its discretion in granting judgment on the pleadings.In their complaint, Appellants alleged that Kroger had violated Ark. Code Ann. 4-75-501(a)(2) through its Kroger Plus Card policies and procedures. Thereafter, the General Assembly passed a bill that was signed into law (Act 850) that defined that parameters of section 4-75-501 in a way that was not previously set forth in the statute. Kroger moved for judgment on the pleadings, which the circuit court granted. The Supreme Court affirmed, holding (1) Act 850 cannot be given retroactive application; (2) the circuit court did not abuse its discretion by applying the "functional availability" doctrine in dismissing the complaint; and (3) the absence of any factual allegation regarding the mens rea was fatal to this cause of action. View "Rhodes v. The Kroger Co." on Justia Law