State of Arkansas v. Wendi Carol Williams

Summary

The Supreme Court of Arkansas dismissed the State's appeal from an order dismissing a state theft charge on double-jeopardy grounds after the defendant pleaded guilty to federal bank fraud based on the same conduct. The court held that the appeal did not qualify for review under Arkansas Rule of Appellate Procedure–Criminal 3(c) because it involved application of law to case-specific facts rather than an issue requiring interpretation for the correct and uniform administration of criminal law. Three justices dissented, concluding that the appeal presented a recurring statutory-interpretation issue under Arkansas Code section 5-1-114.

Holdings

1. The State's appeal was not properly reviewable because it presented only the application of the law to the facts of this case and did not require interpretation of criminal law with widespread ramifications for the correct and uniform administration of justice.

Questions Presented

1. Whether the Supreme Court of Arkansas had authority under Ark. R. App. P.—Crim. 3(c) to hear the State's appeal from dismissal of the theft charge.
2. Whether the State's challenge presented an issue of statutory interpretation with widespread ramifications, rather than merely an application of law to the facts of this case.

Disposition

dismissed