Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the circuit court's award of attorney's fees to Plaintiff in his illegal-exaction lawsuit successfully challenging the constitutionality of certain legislative acts but remanded for further proceedings, holding that attorney's fees were permitted and that the matter should be remanded to the circuit court with instructions to consider the factors set forth in Chrisco v. Sun Industries, Inc., 800 S.W.2d 717 (Ark. 1990), in determining whether the amount of fees requested by Plaintiff was reasonable under the circumstances.The circuit court awarded attorney's fees to Plaintiff in the amount of $323,266 based on Plaintiff's illegal-exaction suit alleging that certain legislative acts of 2015 appropriating funds from the Arkansas General Improvement Fund (GIF) to eight regional planning and developmental districts were unconstitutional. The amount was one-third of the remaining GIF funds involved. The Supreme Court held (1) sovereign immunity was not an issue in this case; (2) attorney's fees were permitted in this case; and (3) because the circuit court did not make any findings with respect to what a reasonable attorney's fee would be in this case, the case must be remanded for reconsideration of the amount of attorney's fees. View "Walther v. Wilson" on Justia Law

The Supreme Court reversed the order of the circuit court denying Mother's petition to terminate the guardianship of her two minor children, holding that the circuit court erred in finding that it remained in the best interest of the children to leave the guardianship intact.The children's paternal grandparents filed a petition for emergency and permanent guardianship of the children after Mother's husband was charged with the sexual abuse of the older child. The circuit court granted the grandparents a permanent guardianship, finding that it was in the best interest of both children for the guardianship to be granted. Mother later filed a petition to terminate the guardianship due to a material change in circumstances. The circuit court denied the petition. The Supreme Court reversed, holding (1) a fit parent who did not consent to a guardianship must be afforded a natural parent's constitutional right to raise her child without undue interference from the government; (2) Mother was entitled to the fit-parent presumption that the guardianship was no longer necessary when she filed her petition to terminate the guardianship; and (3) the presumption that Mother acted in her children's best interest was not rebutted on the record. View "Hartman v. Reardon" on Justia Law

The Supreme Court affirmed the circuit court's denial of Appellant's petition for writ of habeas corpus filed under Ark. Code Ann. 16-112-101, holding that the circuit court did not err in denying the petition.Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court reversed the judgment and remanded the case for a new trial. On retrial, Appellant was again convicted of murder and sentenced to life imprisonment. Appellant later filed the instant petition, arguing that the judgment in his case was invalid because a key witness recanted her trial testimony. The circuit court denied the petition. The Supreme Court affirmed, holding Appellant's claim was an attack on the sufficiency of the evidence, which was not cognizable in habeas proceedings. View "Foreman v. State" on Justia Law

The Supreme Court denied Petitioner's petition to reinvest jurisdiction in the trial court to consider a petition for writ of error coram knobs, holding that Petitioner failed to demonstrate that the writ should issue.Petitioner was sentenced to forty years' imprisonment for first-degree murder and being a felon in possession of a firearm. In the instant petition, Petitioner argued that the judgment-and-commitment order was silent as to whether he should serve 100 percent of his sentence and that his trial counsel provided ineffective assistance. The Supreme Court denied the petition, holding that Petitioner's claims either did not demonstrate some fundamental error of fact extrinsic to the record for which coram nobis relief would be applicable or were not cognizable in a coram nobis proceeding. View "Jones v. State" on Justia Law

The Supreme Court reversed the circuit court's order holding the Arkansas Department of Human Services (DHS) in contempt but dismissed DHS's appeal of a temporary restraining order enjoining its emergency rule, holding that DHS did not violate the express terms of the circuit court's preliminary injunction order by promulgating the emergency rule and that the appeal from the temporary restraining order was moot.The Supreme Court previously upheld the circuit court's temporary restraining order enjoining the 2015 ARChoices Medicaid waiver rule as applied to the named plaintiffs. On remand, the circuit court entered a permanent injunction against the program, and DHS was permanently enjoined from using the methodology embraced by that rule unless it was "properly promulgated." Thereafter, DHS promulgated an emergency rule utilizing the same methodology. The circuit court entered a temporary restraining order against the rule and held DHS in contempt of its permanent injunction order, concluding that DHS failed to provide notice and an opportunity for public comment during the adoption of the emergency rule. The Supreme Court disagreed, holding (1) the emergency rule was properly promulgated under the Administrative Procedure Act's emergency rule making provision; and (2) therefore, DHS did not violate the express terms of the circuit court's permanent injunction order when adopting the emergency rule. View "Arkansas Department of Human Services v. Ledgerwood" on Justia Law

The Supreme Court reversed the order of the circuit court denying Appellant a resentencing hearing and imposing a life sentence with parole eligibility pursuant to the Fair Sentencing of Minors Act (FSMA), holding that because Appellant had his sentence vacated pursuant to Miller v. Alabama, 567 U.S. 460 (2012), Appellant was not subject to sentencing under the FSMA.Appellant was convicted of capital murder for an offense he committed when he was less than eighteen years of age. The jury sentenced Appellant to life imprisonment without the possibility of parole. Appellant's sentence was later vacated pursuant to Miller. Before the resentencing hearing, the Arkansas General Assembly passed the FSMA. The circuit court sentenced Appellant under the FSMA to a term of life imprisonment with the possibility of parole after thirty years. After the circuit court's order, the Supreme Court decided Harris v. State, 547 S.W.3d 64, in which the Court determined that individuals who had their sentences vacated pursuant to Miller were not subject to sentencing under the FSMA. On appeal, Appellant argued that his case should be controlled by Harris even where Harris was handed down after the circuit court's ruling. The Supreme Court agreed and remanded the case for resentencing in accordance with Harris. View "Williams v. State" on Justia Law

The Supreme Court denied Petitioner's fifth pro se petition requesting permission to proceed with a petition for writ of error coram nobis in the trial court, holding that Petitioner did not satisfy any ground for granting the writ and failed to offer facts sufficient to warrant granting leave to proceed in the trial court for the writ.Petitioner was convicted of first-degree murder and sentenced to life imprisonment. In his petition, Petitioner requested permission to reinvest jurisdiction in the circuit court to file a petition for writ of error coram nobis on the grounds of prosecutorial misconduct. The Supreme Court denied the writ, holding that Petitioner's arguments in support of the writ were without merit and that Petitioner failed to demonstrate prejudice. View "Scott v. State" on Justia Law

The Supreme Court affirmed the circuit court's entry of a $650 deficiency judgment against the Arkansas State Highway Commission after a jury determined that the Commission owed KW-DW Properties, LLC $36,000 for just compensation in an eminent domain action, holding that substantial evidence supported the verdict, there was no error in the amount of recovery, and the circuit court did not abuse its discretion in denying KW-DW's motion for a new trial.The Commission filed a declaration taking approximately 2.36 acres of KW-DW's property for a highway project. The matter proceeded to a jury trial for final determination of the compensation due. The jury determined the final, just compensation due to be $36,000. The Supreme Court affirmed, holding that, while the motion for a new trial was timely, it nonetheless provided no basis for reversal. View "KW-DW Properties, LLC v. Arkansas State Highway Commission" on Justia Law

The Supreme Court reversed the judgment of the circuit court entered on the jury's verdict finding that Davis Life Care Center (DLCC), a long-term care facility, was not entitled to charitable immunity and denying DLCC's motion for new trial, holding that the circuit court erred in submitting the charitable-immunity question to the jury.Plaintiff sued DLCC alleging negligence, medical malpractice, breach of an admission agreement, and other causes of action. DLCC filed a motion for summary judgment claiming entitlement to charitable immunity. The circuit court granted the motion. The court of appeals reversed and remanded for further proceedings, concluding that reasonable persons could reach different conclusions based on the undisputed facts presented. The circuit court submitted the question of charitable immunity to the jury, which returned a verdict against DLCC. The Supreme Court reversed, holding that the issue of charitable immunity is a question of law for the court, rather than the jury, to decide. View "Davis Nursing Ass'n v. Neal" on Justia Law

The Supreme Court dismissed the appeal brought by the Arkansas Department of Humanitarian Services (DHS) challenging the permanent injunction against its 2015 ARChoices Medicaid waiver rule, holding that this case was moot.During the course of this appeal, DHS promulgated a new rule. The circuit court found that DHS had properly promulgated the rule and dissolved the injunction. DHS argued before the Supreme Court that two exceptions to the mootness doctrine - matters capable of repetition yet evading review and matters of substantial public interest that are likely to be litigated in the future - applied in this case. The Supreme Court disagreed and dismissed this appeal, holding that none of the exceptions to the mootness doctrine applied. View "Arkansas Department of Human Services v. Ledgerwood" on Justia Law