Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court denied Petitioner's request that the Supreme Court reinvest jurisdiction in the trial court so that it may consider a writ of error coram nobis, holding that Petitioner's petition was without merit.Petitioner was convicted of capital murder. In his coram nobis petition Petitioner primarily disputed the sufficiency of the evidence and also alleged various trial errors and ineffective assistance of counsel. The Supreme Court denied the petition, holding that Petitioner's petition either did not state claims that were cognizable in a coram nobis proceeding or failed to identify any facts to support the basis for the writ that he alleged. View "Johnson v. State" on Justia Law

The Supreme Court denied Petitioner's petition seeking to reinvest jurisdiction in the trial court so that he may proceed with a petition for writ of error coram nobis in his criminal case, holding that error coram nobis was not available to address Petitioner's claims.In his petition, Petitioner argued that the writ should issue because there were flaws in his trial and in his direct appeal, including trial error, prosecutorial misconduct, due process violations, and ineffective assistance of counsel. The Supreme Court denied relief, holding that Petitioner did not allege grounds for the writ because none of his claims were based upon information outside of the record or otherwise unknown to Petitioner. View "Williams v. State" on Justia Law

The Supreme Court reversed the order of the circuit court denying Defendant's motion to dismiss a claim brought under the Arkansas Whistle-Blower Act (AWBA) and dismissed the complaint, holding that the complaint was barred by the State's sovereign immunity.Plaintiff, who had worked in the office of the Arkansas Treasurer of State before he was terminated, filed a complaint against Defendant, the treasurer, in his official capacity, alleging a violation of the AWBA. Defendant filed a motion to dismiss, alleging that the complaint was barred by sovereign immunity. The trial court denied the motion to dismiss. The Supreme Court reversed, holding (1) pursuant to the Court's decision in Arkansas Community Correction v. Barnes, 542 S.W.3d 841 (Ark. 2018), the purported legislative waiver of the State's sovereign immunity in the AWBA is unconstitutional; and (2) the complaint in this case was barred by sovereign immunity. View "Milligan v. Singer" on Justia Law

The Supreme Court affirmed the circuit court's grant of summary judgment to Appellees on Appellant's negligence and civil rights claims, holding that summary judgment was properly granted.Appellant, as special administrator of the estate of his deceased son, filed a wrongful death action against the City of Little Rock and others over the City's alleged mishandling of a 911 call seeking rescue services for his son. The circuit court granted summary judgment in favor of the City. The Supreme Court affirmed, holding (1) the City proved entitlement to municipal immunity under Ark. Code Ann. 21-9-301; and (2) the circuit court did not err in granting summary judgment on Appellant's civil rights claims brought under 42 U.S.C. 1983. View "Yang v. City of Little Rock, Arkansas" on Justia Law

The Supreme Court denied Petitioner's petition in which he requested that the Supreme Court reinvest jurisdiction in the trial court so that he may file a petition for writ of error coram nobis and audita querela, holding that Petitioner failed to set out a basis in the original petition or in his amended petitions that would support issuance of the writ.Petitioner was convicted of first-degree murder and sentenced to life in prison without possibility of parole. The Supreme Court affirmed. Petitioner then filed the instant petition, alleging, among other things, Brady claims. The Supreme Court denied the petition, holding (1) with the exception of the Brady claims, none of Petitioner's proposed grounds for the writ were cognizable in proceedings for the writ or fell within one of the recognized categories of error to support the writ; and (2) Petitioner's allegations concerning his Brady violation claims were too vague and conclusory and lacked the requisite factual support. View "Alexander v. State" on Justia Law

The Supreme Court dismissed the State's interlocutory appeal from the circuit court's grant of David Reynolds's motion to suppress evidence seized from a search of his cell phone, holding that this was not a proper State appeal.The State appealed under Rule 3 of the Arkansas Rules of Appellate Procedure-Criminal. Noting that an appeal is permitted by Rule 3 when the issue presented is whether the circuit court erred in its interpretation of the law and that the Court does not accept an appeal by the State when the circuit court's decision turns on facts unique to the case or involves a mixed question of law and fact, the Supreme Court dismissed the appeal, holding that the correct and uniform administration of the criminal law was not at issue in this case. View "State v. Reynolds" on Justia Law

The Supreme Court reversed the circuit court's order denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing with Minors Act of 2017 (FSMA), holding that the penalty provisions of the FSMA did not apply to Appellant.In 2000, Appellant pled guilty to capital murder and received a mandatory sentence of life in prison without parole. Appellant was sixteen years old at the time of the murder. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), the circuit court granted habeas relief and vacated Appellant's life-without-parole sentence and remanded his case for resentencing. Before a resentencing hearing was held, however, the General Assembly passed the FSMA, which eliminated life without parole as a sentencing option for juvenile offenders and extended parole eligibility to juvenile offenders. On remand, the circuit court sentenced Appellant under the FSMA to life in prison with parole eligibility after thirty years. The Supreme Court reversed, holding (1) because Appellant committed his crime before the effective date of the FMSA, the penalty provisions of the Act did not apply to him; and (2) Appellant was no longer serving a sentence to which parole eligibility could attach. View "Elliott v. State" on Justia Law

The Supreme Court dismissed Appellant's appeal from the judgment of the trial court dismissing Appellant's pro se petition and two amendments in which he sought a writ of audita querela, thus rendering moot Appellant's pro se motion in which he sought to file his reply brief belatedly, holding that Appellant was not entitled to relief.Appellant was convicted of furnishing prohibited articles. Appellant later filed his petition and amendments seeking a writ of audita querela. The trial court dismissed Appellant's petition and amendments on the ground that the writ of audita querela is not recognized and, therefore, the court was without jurisdiction to modify the judgment. The Supreme Court dismissed Appellant's appeal, holding that he could not prevail on appeal because, although the trial court had jurisdiction to provide relief through a writ of error coram nobis, Appellant stated no basis for issuance of the writ. View "Gonder v. State" on Justia Law

In this case in which Debbie Worsham was awarded damages on her breach of contract action the Supreme Court affirmed the judgment of the circuit court denying Worsham's motion for attorney's fees and costs and Worsham's motion for reconsideration, holding that Worsham's motion for attorney's fees was untimely.On appeal, Worsham argued that she was entitled to attorney's fees pursuant to Ark. Code Ann. 16-22-308 and that the circuit court erred in denying her motion for attorney's fees because it was timely under Ark. R. Civ. P. 54(e). The Supreme Court affirmed the circuit court's denial of Worsham's motion for attorney's fees, holding (1) the circuit court correctly found that the attorney's fees motion was untimely; and (2) Worsham's argument that she was entitled to attorney's fees under section 16-22-308 was without merit. View "Worsham v. Day" on Justia Law

The Supreme Court dismissed as moot Petitioner's petition for an order compelling Arkansas Attorney General Leslie Rutledge to certify the popular name and ballot title of a proposed amendment to the Arkansas Constitution, holding that Act 387 of 2019 rendered the original action petition moot.The proposed amendment in this case was entitled "The Arkansas Recreational Marijuana Amendment of 2020." Petitioner Arkansas True Grass was a ballot question committee that sponsored the proposed amendment. After the Attorney General rejected the popular name and ballot title of the proposed amendment, Petitioner asked the Supreme Court to require that the Attorney General certify the proposed measure. In response, the Attorney General asked the Supreme Court to dismiss the petition as moot in light of the passage of Act 387, which eliminated the requirement that sponsors of initiative petitions obtain the Attorney General's certification of the proposed amendment's popular name and ballot title prior to circulation of the initiative petition. The Supreme Court agreed and dismissed the original action petition, holding that Petitioner's request was moot because the Attorney General's certification would have no practical legal effect on the parties. View "Arkansas True Grass v. Rutledge" on Justia Law