| BHC Pinnacle Pointe Hospital, LLC v. Nelson |
| Citation: 2020 Ark. 70 Opinion Date: February 20, 2020 Judge: Karen R. Baker Areas of Law: Arbitration & Mediation, Labor & Employment Law |
| In this interlocutory appeal, the Supreme Court reversed the order of the circuit court denying BHC Pinnacle Point Hospital, LLC's motion to compel arbitration of a class action complaint filed by Employees, individually and on behalf of all others similarly situated, holding that Employees' claims fell within the scope of their voluntary arbitration agreements with Pinnacle Pointe. In their complaint, Employees alleged that Pinnacle Point violated the minimum wage and overtime provisions of the Arkansas Minimum Wage Act (AMWA), Ark. Code Ann. 11-4-201 et seq. Pinnacle Point filed a motion to dismiss the complaint and compel arbitration, asserting that Employees' claims fell within the scope of their respective alternative resolution for conflicts agreements they executed with Pinnacle Pointe. The circuit court denied the motion. The Supreme Court reversed, holding that the circuit court erred as a matter of law in denying Pinnacle Pointe's motion to compel arbitration. |
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| Collier v. Kelley |
| Citation: 2020 Ark. 77 Opinion Date: February 20, 2020 Judge: Hudson Areas of Law: Criminal Law |
| The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's petition for writ of habeas corpus, holding that Appellant failed to state a basis for issuance of the writ. Appellant pleaded guilty to first-degree murder and other crimes. In his habeas petition, Appellant argued that the judgments in three counties reflected the incorrect legal name, making the convictions facially invalid. The circuit court declined to issue the writ. The Supreme Court affirmed, holding that Appellant's challenge to the misnomer on the judgment and commitment orders was a mere allegation of trial error and not the type of defect that implicates the facial validity of a trial court's judgment or jurisdiction. |
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| Hayes v. Kelley |
| Citation: 2020 Ark. 79 Opinion Date: February 20, 2020 Judge: Wood Areas of Law: Criminal Law |
| The Supreme Court affirmed the circuit court's order denying Appellant's petition for a writ of habeas corpus filed pursuant to Ark. Code Ann. 16-112-101, holding that Appellant did not state a ground for the writ. Appellant pled guilty to four counts of first-degree sexual assault. At the time of the trial court proceedings, Appellant requested a mental evaluation. After the circuit court granted the request Appellant withdrew the request and pled guilty. Thereafter, the forensic evaluation was submitted to the court with a finding that Appellant was competent and fit to proceed. In his habeas corpus petition, Appellant argued that the circuit court lacked subject matter jurisdiction to accept his guilty plea before the mental evaluation was filed. The circuit court denied the petition. The Supreme Court affirmed, holding that Appellant's claim was one that fell within the scope of habeas, but Appellant's claim that the circuit court was divested of jurisdiction due to the lack of a forensic report at that time of the proceeding failed. |
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| Hundley v. State |
| Citation: 2020 Ark. 89 Opinion Date: February 20, 2020 Judge: Womack Areas of Law: Criminal Law |
| The Supreme Court affirmed the judgment of the circuit court rejecting Appellant's proffered jury instructions at his resentencing hearing, holding that the circuit court did not abuse its discretion. At age seventeen, Appellant committed capital murder and rape. Appellant received a mandatory sentence of life without the possibility of parole. After the United States Supreme Court decided Miller v. Alabama, 567 U.S. 460 (2012), Appellant's life sentence for capital murder was vacated. After a resentencing hearing a jury sentenced Appellant to life imprisonment. On appeal, Appellant argued that the circuit court erred in rejecting his proffered jury instructions on capital murder. The Supreme Court affirmed, holding that because Appellant's proffered instructions would ask the jury to make findings required only in death cases the circuit court properly refused to give those instructions. |
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| Johnson v. State |
| Citation: 2020 Ark. 86 Opinion Date: February 20, 2020 Judge: Womack Areas of Law: Criminal Law |
| The Supreme Court denied Appellant's petition for rehearing of the Court's decision affirming the circuit court's denial of Appellant's petition for postconviction DNA testing under Act 1780, holding that Appellant's petition for rehearing failed to comport with the requirements set forth in Arkansas Supreme Court Rule 2-3(g). On appeal from the denial of his postconviction motion, the Supreme Court affirmed the conclusion of the circuit court that the proposed scientific testing under Act 1780 could not raise a reasonable probability that Defendant did not commit the murder for which he was convicted and that the admissibility of proffered eyewitness identification testimony was procedurally barred from consideration. In his petition for rehearing, Appellant reiterated the same arguments that were considered and rejected on appeal and, for the first time, asserted a constitutional claim. The Supreme Court denied the petition for rehearing, holding that the entirety of the petition fell outside the scope of rehearing under Rule 2-3(g). |
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| Lovelace v. Kelley |
| Citation: 2020 Ark. 91 Opinion Date: February 20, 2020 Judge: Womack Areas of Law: Criminal Law |
| The Supreme Court affirmed the judgment of the circuit court denying and dismissing Appellant's duplicate petitions for writ of habeas corpus, holding that the petitions failed to allege a basis for the writ. Approximately forty years ago, Appellant was convicted of aggravated robbery and sentenced to life imprisonment. This appeal concerned the circuit court's denial and dismissal of his duplicate pro se petitions for writ of habeas corpus. In his petitions, Appellant asserted that his conviction was void because the criminal information was signed by the deputy prosecuting attorney instead of the elected prosecuting attorney. The circuit court denied and dismissed the petitions. The Supreme Court affirmed, holding that the circuit court did not clearly err. |
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| Mabry v. State |
| Citation: 2020 Ark. 72 Opinion Date: February 20, 2020 Judge: Hudson Areas of Law: Criminal Law |
| The Supreme Court affirmed Defendant's conviction of six counts of rape, holding that no reversible error occurred in the proceedings below. Defendant was sentenced for life imprisonment for each count of rape, with the sentences to be served consecutively. Because Defendant received a sentence of life imprisonment, the Supreme Court reviewed the record for all errors prejudicial to Defendant. The Supreme Court affirmed, holding that the circuit court did not commit prejudicial error (1) in denying Defendant's motion for a directed verdict because substantial evidence supported the conviction; (2) in making three evidentiary rulings; and (3) in denying Defendant's motion for a mistrial. |
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| Marshall v. State |
| Citation: 2020 Ark. 66 Opinion Date: February 20, 2020 Judge: Kemp Areas of Law: Criminal Law |
| The Supreme Court affirmed the judgment of the trial court denying Appellant's pro se petition for postconviction relief filed pursuant to Ark. R. Crim. P. 37.1, holding that the trial court did not clearly err when it denied relief. Appellant was convicted of aggravated residential burglary and sentenced to a term of life imprisonment. In his postconviction relief petition, Appellant alleged that counsel ineffectively requested trial continuances without legal bases or good cause, thus depriving him of his speedy trial rights. The trial court denied the petition. The Supreme Court affirmed, holding that, even assuming that counsel's requests delayed Appellant's trial without a legal basis, Appellant failed to demonstrate that he was prejudiced as a result of those alleged errors. |
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| Mcarty v. State |
| Citation: 2020 Ark. 68 Opinion Date: February 20, 2020 Judge: Karen R. Baker Areas of Law: Criminal Law |
| The Supreme Court affirmed the orders of the circuit court denying Appellant's two pro se petitions challenging his 1993 conviction for first-degree murder and sentence of life imprisonment, holding that the circuit court properly denied relief. The first petition Appellant filed sought scientific testing for habeas relief under Act 1780 of 2001 Acts of Arkansas, codified at Ark. Code Ann. 16-112-201 to -208. The second petition sought relief from an illegal sentence. The circuit court denied both petitions. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief under Act 1780; and (2) Appellant failed to allege facts that would support his claim of an illegal sentence. |
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| Young v. Kelley |
| Citation: 2020 Ark. 84 Opinion Date: February 20, 2020 Judge: Wynne Areas of Law: Criminal Law |
| The Supreme Court affirmed the order of the circuit court denying and dismissing Appellant's pro se petition for writ of habeas corpus pursuant to Ark. Code Ann. 16-112-101, holding that Appellant stated no ground in the petition on which the writ could issue under Arkansas law. Appellant pled nolo contendere to two counts of second-degree sexual assault. Appellant later filed the petition for writ of habeas corpus alleging claims of actual innocence and insufficient evidence. The circuit court denied the dismissed the petition. The Supreme Court affirmed, holding (1) Appellant did not meet his burden of demonstrating that he was being illegally detained and entitled to issuance of a writ of habeas corpus to effect his release from custody; and (2) Appellant offered no well-founded argument for the Court to expand the writ. |
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| Chekuri v. Nekkalapudi |
| Citation: 2020 Ark. 74 Opinion Date: February 20, 2020 Judge: Hudson Areas of Law: Family Law |
| The Supreme Court affirmed the order of the circuit court granting Appellant a divorce, dividing the parties' marital property, and awarding alimony to Appellee, holding that the circuit court's rulings were not clearly erroneous. The parties in this case entered into an arranged marriage in India. Approximately one year later, Appellant filed a complaint for divorce. After the divorce decree was entered Appellant appealed. The Supreme Court affirmed, holding that the circuit court (1) did not err by equally dividing the funds that Appellant spent during the parties' separation; (2) did not err in deciding to divide equally the marital assets; and (3) did not err by awarding Appellee rehabilitative alimony. |
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