Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court affirmed the trial court’s denial and dismissal of Appellant’s petition for writ of error coram nobis, holding that Appellant failed to demonstrate that the trial court abused its discretion in denying relief.Appellant entered a negotiated guilty plea to kidnapping and second-degree murder for an aggregate sentence of 480 months’ imprisonment. Appellant later filed a petition seeking a writ of coram nobis, alleging a Brady violation and ineffective assistance of counsel. The trial court denied the writ. The Supreme Court affirmed, holding (1) Appellant failed to demonstrate that the evidence that was allegedly suppressed was sufficient to alter the outcome of the trial; and (2) there was no error in the trial court’s conclusion that Appellant’s allegations of ineffective assistance were not cognizable. View "Osburn v. State" on Justia Law

The Supreme Court reversed the judgment of the trial court convicting Defendant of manslaughter after a third trial and remanded this case for a new trial, holding that Defendant should have been permitted to argue that he believed he was acting in self-defense and to have a jury instruction on that point.Defendant was charged with manslaughter. On appeal, Defendant argued that the circuit court erred by not giving his proffered jury instruction on justification and by denying him his request to argue that he believed he was acting in self-defense. The Supreme Court agreed, holding that a justification such as self-defense is considered an element of the offense and, once raised, must be disproved by the prosecution beyond a reasonable doubt. View "Schnarr v. State" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court denying Appellant’s motion to proceed in forma pauperis and ordering the Arkansas Department of Correction to withhold the applicable filing fee from Appellant's inmate account, holding (1) there was no error in including Appellant’s Veterans’ Administration disability benefits in determining Appellant’s indigency status pursuant to federal law; but (2) applicable federal law prohibits the circuit court from ordering that the filing fee be paid from Appellant’s trust account where the account proceeds are derived entirely from Appellant’s disability benefits. View "Halfacre v. Kelley" on Justia Law

The Supreme Court dismissed Convent Corporation’s appeal from an order of the circuit court upholding the City of North Little Rock’s decision to condemn a business property, holding that pursuant to the holdings in Haile v. Ark. Power & Light Co., 907 S.W.2d 122 (Ark. 1995), and Ratzlaff v. Franz Foods of Ark., 500 S.W.2d 379 (Ark. 1995), this appeal must be dismissed.Specifically, the Court held that because Convent Corporation had multiple claims and voluntarily dismissed one without prejudice, Rule 2 of the Arkansas Rule of Appellate Procedure-Civil required that the appeal be dismissed in order to avoid piecemeal appeals. View "Convent Corp. v. City of North Little Rock" on Justia Law

The Supreme Court dismissed this appeal from the judgment of the court of appeals reversing the decision of the circuit court, vacated the court of appeals’ decision, and reinstated the decision of the circuit court, holding that the appeal was procedurally barred.The underlying case involved child support from Wyndham Dempster to be paid to Chelsea Harley. After the circuit court determined Dempster’s arrearages, Harley appealed. The court of appeal dismissed Harley’s appeal for lack of standing. On rehearing, the court of appeals determined that Harley had standing to bring the appeal and reversed the circuit court’s determination. Dempster filed a petition for review, which the Supreme Court granted. Harley, however, filed to timely file a brief for the Court’s consideration. The Supreme Court dismissed the appeal and vacated the court of appeals’ opinion, holding that even if Harley’s appeal would not be barred for lack of standing, there would be no argument for reversal on the merits for the Court to consider where Harley failed to timely file a brief. View "Harley v. Dempster" on Justia Law

The Supreme Court reversed the order of the circuit court granting Burger King’s motion for summary judgment in an action seeking relief from a tax assessment pursuant to Ark. Code Ann. 26-18-406, holding that the circuit court erred in interpreting the relevant statutes and promulgated rules to find that Burger King was only required to pay taxes on the wholesale value of the food ingredients removed from stock as opposed to the retail value of the meals.On appeal, the Supreme Court agreed with the interpretation of the statutes and rules set forth by the Director of the Arkansas Department of Finance and Administration, holding that items withdrawn from stock by Burger King should be taxed at the advertised retail price rather than the actual wholesale cost - the original purchase price. View "Walther v. FLIS Enterprises, Inc." on Justia Law

The Supreme Court denied Appellant’s motion asking the Court to recall its mandate in his direct appeal affirming his conviction for capital murder and death sentence, holding that Appellant failed to demonstrate a breakdown in the appellate process to justify the recall of the direct-appeal mandate.Appellant filed a motion to recall the mandate and stay his execution, arguing that he did not receive the minimum due-process requirements set forth in Ake v. Oklahoma, 470 U.S. 68 (1985), because the Court had incorrectly interpreted and applied Ake, thus denying him access to an independent mental health expert to assist in his defense. The Supreme Court denied Appellant’s motion and lifted the stay of his execution, holding that there was no breakdown in the appellate process that would warrant recalling the mandate. View "Davis v. State" on Justia Law

The Supreme Court affirmed Defendant’s conviction of capital murder and life sentence without the possibility of parole as required by law, holding that there was no reversible error in the proceedings below.On appeal, Defendant argued that the trial court erred by allowing a witness to the crime to testify and, in the alternative, in denying his motion for a continuance. Defendant argued specifically that the trial court erred as regards this issue due to the relatively late disclosure of the State’s intent to have the witness testify. The Supreme Court affirmed, holding that, under the circumstances, the trial court did not abuse its discretion by allowing the witness to testify or by denying Defendant’s request for a continuance. View "Duncan v. State" on Justia Law

In this death-penalty case, the Supreme Court denied Petitioner’s request to recall the mandate for his resentencing in Ward v. State, 1 S.W.3d 1, 3 (1998) (Ward III), holding that Petitioner failed to meet the standard for the Court to recall the mandate in Petitioner’s resentencing.After the governor set Petitioner’s execution date, Petitioner filed a motion to recall the mandate in this matter and stay of execution until the United States Court issued its opinion in McWilliams v. Dunn, 137 S. Ct 1790 (2017). Petitioner argued that McWilliams had a direct impact on his claim pursuant to Ake v. Oklahoma, 470 U.S. 68 (1985), and that the Court should overrule precedent holding that a competency evaluation at the Arkansas State Hospital satisfies Ake. The Supreme Court granted the stay of execution, took the motion as a case, and then denied Petitioner’s motion, holding (1) McWilliams did not develop new law or change the standard pursuant to Ake; and (2) based on law-of-the-case doctrine, Petitioner’s arguments provided no basis for granting his motion to recall the mandate in his resentencing. View "Ward v. State" on Justia Law

The Supreme Court reversed and remanded this case to the Workers’ Compensation Commission for further proceedings, holding that the evidence indicating that Deputy Cleon Morgan was an independent contractor and, therefore, there was not substantial evidence to support the Commission’s decision that Morgan was an employee at the time of his injury.The Commission found that, at the time of his injury, Deputy Morgan had two employers, the Jefferson County Sheriff’s Department and Brookshire Grocery Company. The Commission concluded that both were liable for Deputy Morgan’s workers’ compensation benefits as “joint employers.” Brookshire appealed. The Supreme Court reversed the Commission’s decision, holding that where all the factors that are to be considered in determining if Deputy Morgan was an employee or an independent contractor indicate that Deputy Morgan was an independent contractor, the case must be remanded for further proceedings for a determination as to whether Brookshire was indeed liable for workers’ compensation benefits. View "Brookshire Grocery Co. v. Morgan" on Justia Law