Justia Arkansas Supreme Court Opinion Summaries

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The Supreme Court dismissed as moot Appellants' appeal of the circuit court's temporary restraining order (TRO) that enjoined the Arkansas State Plant Board from enforcing its agency rule limiting the use of dicamba herbicides after April 16, 2018, holding that the appeal was moot.On April 16, 2018, thirty-seven Arkansas farmers who intended to use dicaamba herbicides in 2018 (Appellees), filed a complaint against the Plant Board seeking a declaratory judgment and injunctive relief. The circuit court granted a TRO and enjoined the Plant Board from enforcing its April 15 cutoff date. The Plant Board appealed. On February 27, 2019, the Plant Board promulgated a new rule that repealed the April 15 cutoff date and took effect beginning March 9, 2019. The Supreme Court dismissed the interlocutory appeal as moot, holding that judgment on this appeal would have no practical effect upon the TRO's enforceability. View "Arkansas State Plant Board v. Bell" on Justia Law

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The Supreme Court affirmed Defendant's convictions of two counts of premeditated and deliberate capital murder and sentencing him to life imprisonment without parole for each murder, holding that there was no prejudicial error in the proceedings below.Specifically, the Court held that the circuit court (1) did not abuse its discretion or deprive Appellant of his constitutional right to present a defense by excluding evidence that Appellant argued linked another person to the crimes; and (2) did not abuse its discretion in allowing testimony concerning what a person could see with a telescopic sight mounted on Appellant's rifle. View "Barefield v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the order of the circuit court terminating Mother's parental rights to her son, holding that the circuit court did not commit reversible error by denying Mother's counsel's motion to withdraw.The Arkansas Department of Human Services opposed the motion to withdraw, arguing that Mother had been served under Ark. R. Civ. P. 5 and that she had over a month to fire her attorney and hire a new one. The circuit court denied the motion. On appeal, Mother argued that, by denying the motion, the circuit court violated her Sixth Amendment right to counsel of one's choosing. The Supreme Court affirmed, holding that the denial of the motion to withdraw was not an issue preserved on appeal and that, even if this Court were to consider the merits of Mother's constitutional claims, her argument would still fail. View "Langston v. Arkansas Department of Human Services" on Justia Law

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The Supreme Court dismissed Appellant's appeal from the denial of his pro se petition to proceed in forma paupers in a habeas proceeding, holding that the circuit court did not abuse its discretion in finding that Appellant should not be permitted to proceed at public expense.In denying the petition for writ of habeas corpus the circuit court found that the petition did not contain a colorable cause of action. The Supreme Court dismissed Appellant's appeal, which rendered moot Appellant's motion for extension of time to file his brief-in-chief, holding that Appellant's assertions and allegations were either not cognizable in habeas proceedings or brought without factual substantiation or development. View "Watson v. Kelley" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the Arkansas Workers' Compensation Commission adopting the finding of an administrative law judge (ALJ) that Appellant's additional benefits claim was barred by the statute of limitations, holding that the Commission did not err in finding that Appellant's claim was barred by the statute of limitations.After a hearing, the ALJ found that Appellant's claim was barred by the statute of limitations. The Commission affirmed and adopted the ALJ's findings. The court of appeals reversed, concluding that the statute of limitations had tolled. The Supreme Court vacated the opinion of the court of appeals and affirmed the Commission's finding, holding that the Commission's decision was supported by substantial evidence. View "Farris v. Express Services, Inc." on Justia Law

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The Supreme Court dismissed Appellants' appeal from the order of the circuit court granting Appellees' motion for sanctions, holding that the order was not final.Appellant filed a personal injury complaint against Appellees. When Appellees discovered inconsistencies in Appellant's testimony and discovery responses, Appellees filed a motion for sanctions seeking dismissal of the complaint and an allocation of costs and fees. The circuit court granted the motion. Appellant and two attorneys filed a notice of appeal. The Supreme Court dismissed the appeal, holding that the Ark. R. Civ. P. 11 order was not final under the facts of this case. View "McHughes v. Wayland" on Justia Law

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The Supreme Court affirmed the circuit court's order granting summary judgment in favor of Appellee in this contract dispute, holding that the circuit court did not err in concluding that Appellee's loan to Appellant was payable on demand because the loan agreement did not have a maturity date.After Appellee demanded repayment of his loan and Appellant refused Appellee sued for repayment of the loan and attorney's fees. The circuit court granted Appellee's summary judgment motion, concluding that because the loan did not have a maturity date it was payable on demand. The court also awarded Appellee attorney's fees. The court of appeals reversed, holding that genuine issues of material fact existed as to whether the loan agreement was an on-demand contract. The Supreme Court vacated the opinion of the court of appeals and affirmed the judgment of the circuit court, holding (1) because the loan agreement was silent as to the maturity date, it was payable on demand; and (2) the attorney's fees and costs award was proper. View "Miracle Kids Success Academy, Inc. v. Maurras" on Justia Law

Posted in: Contracts
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The Supreme Court dismissed the State's appeal from the circuit court's decision to dismiss criminal charges against Defendant for violation of his speedy-trial rights, holding that Ark. R. App. P.-Crim. 3(d) prohibited this Court from considering the appeal.Defendant was arrested based on allegations that he had sexually assaulted his children. After the trial court granted the State six continuances Defendant filed a motion to dismiss for violation of his speedy-trial rights. The circuit court granted the motion. The State appealed, arguing that the case turned purely on an issue of law. The Supreme Court disagreed, holding that Rule 3(d) did not allow this Court to consider the State's appeal because the circuit court's decision to dismiss the charges turned upon the specific facts of this particular case. View "State v. Jones" on Justia Law

Posted in: Criminal Law
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In this appeal from the circuit court's order certifying a class action lawsuit filed by Employees against Employer, the Supreme Court remanded the case with instructions to enter an order that complies with Ark. R. Civ. P. 23, holding that the order must reflect the circuit court's analysis to determine whether the Rule 23 requirements have been met.Employees filed this suit pursuant to the Arkansas Minimum Wage Act, Ark. Code Ann. 11-4-201 et seq., for unpaid overtime. After filing their complaint Employees moved to certify a class of individuals who were, are, or will be employed by Employer as hourly paid employees. The circuit court granted Employees' motion for class certification. The Supreme Court remanded the case with instructions, holding that, in conformity with Industrial Welding Supplies of Hattiesburg, LLC v. Pinson, 530 S.W.3d 854 (Ark. 2017), the class certification order was deficient. View "Koppers, Inc. v. Trotter" on Justia Law

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The Supreme Court affirmed the circuit court's denial of Appellant's petition for postconvicton relief pursuant to Ark. R. Crim. P. 37, holding that the performance of Appellant's trial counsel was not deficient, and therefore, the circuit court's denial of Appellant's Rule 37 petition was not clearly erroneous.Appellant was convicted of one count of first-degree battery and one count of second-degree battery. After Appellant's convictions and sentences were affirmed on direct appeal, Appellant filed a petition for postconviction relief alleging that his trial counsel was ineffective in failing to investigate and call certain witnesses. The circuit court denied Appellant's petition. The Supreme Court affirmed, holding that Appellant failed to meet his burden under the first prong of Strickland v. Washington, 466 U.S. 668 (1984), because he did not demonstrate that his trial counsel's performance fell below an objective standard of reasonableness. View "Hinton v. State" on Justia Law