Anthony Williamson v. Theodore Brown, Director, Arkansas State Crime Laboratory

2026 Ark. 36

• Court: Supreme Court of Arkansas
• Decided: February 19, 2026
• Status: Published

Opinion

Cite as 2026 Ark. 36 SUPREME COURT OF ARKANSAS No. CV-25-332

Opinion Delivered: February 19, 2026 ANTHONY WILLIAMSON APPELLANT PRO SE APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, TWELFTH DIVISION V. [NO. 60CV-24-2239]

THEODORE BROWN, DIRECTOR, HONORABLE CARA CONNORS, ARKANSAS STATE CRIME JUDGE LABORATORY APPELLEE AFFIRMED.

RHONDA K. WOOD, Associate Justice

Anthony Williamson is serving thirty years’ imprisonment for aggravated robbery

and kidnapping.1 He requested the Arkansas State Crime Laboratory (Crime Lab) provide

him with records. Despite the Crime Lab sending him records relevant to every matter

involving him, he believes he is entitled to more. Because of this dispute, he filed a petition

for declaratory judgment and writ of mandamus. Following a hearing, the circuit court

entered summary judgment for the Crime Lab. It found that Williamson could not identify

any unproduced records for the court to order the Crime Lab turn over. He appeals, and

we affirm the circuit court’s decision.

1 Williamson v. State, 2010 Ark. App. 595. In January 2024, Williamson requested that the Crime Lab produce records related

to fifteen criminal cases under Arkansas Code Annotated section 12-12-312(a)(1)(A)(ii)(a)

(Supp. 2021). It produced all the records of his recent criminal conviction and all his “related

prior criminal cases,” even those he did not seek. Yet it did not provide records for the cases

in which he was not a defendant.

Dissatisfied with the Crime Lab’s responses, Williamson filed a petition for

declaratory judgment and writ of mandamus. The Crime Lab moved for summary judgment

and attached an affidavit by Sammy Williams, a Crime Lab director. Williams affirmed that

all documents related to Williamson’s most recent conviction in case number 66FCR-08-

12362 together with documents connected to previous convictions had been provided to

Williamson.3

At the summary-judgment hearing, both Williams and Williamson testified. Williams

again affirmed that the Crime Lab had provided Williamson with all records connected to

Williamson’s cases. Williams further testified that the additional records requested by

Williamson were not related to his criminal cases. He explained that the other cases also had

2 The record reveals that this criminal docket number from Sebastian County was referred to throughout pleadings and testimony at the hearing as CR-2008-1236. The Crime Lab numbers associated with case number CR-2008-1236, as established by Williams’s affidavit and testimony, are Crime Lab record numbers 2007-012616 and 2007- 018193. Williams explained that record number 2007-018193 included documents connected to a sample prep of collected DNA. 3 Williams’s affidavit and testimony was that the Crime Lab provided Williamson the records from his previous criminal cases bearing Crime Lab record numbers 2005LIT- 13114, 2006-08191, and 2007-004934.

2 DNA samples sent to Orchid Cellmark for testing (likely in the same batch, which explains

why Williamson saw the case numbers in his records).

Williamson introduced over two hundred pages of the records the Crime Lab

provided him. Yet he insisted that more were missing. The circuit court patiently and

extensively asked Williamson to precisely identify what was missing. He could not identify

any documents that the circuit court could not find in the records or that he was entitled to

under the statute. The court granted summary judgment because there were no material

facts in dispute and no justiciable controversy. On appeal, Williamson insists that the circuit

court abused its discretion. We affirm.

Summary judgment is appropriate when there are no genuine issues of material fact

to be litigated and the party is entitled to judgment as a matter of law. Gates v. Hudson, 2025

Ark. 48, at 5, 711 S.W.3d 142, 147. Williamson filed a petition for declaratory relief that

he was entitled to records from the Crime Lab and a writ of mandamus that the court order

the Crime Lab to produce them. Declaratory relief may be granted if the petitioner

establishes (1) that there is a justiciable controversy; (2) that the controversy is between

persons whose interests are adverse; (3) that the party seeking relief has a legal interest in the

controversy; and (4) that the issue involved in the controversy is ripe for judicial

determination. Rogers, 2017 Ark. 267, 527 S.W.3d 719. Additionally, the purpose of a writ

of mandamus is to enforce an established right. Scott v. Sullivan, 2025 Ark. 152, at 4, 720

S.W.3d 865, 868. A petitioner requesting the writ must show a clear and certain right to

the relief sought and the absence of any other adequate remedy. Id.

3 Our de novo review reflects that on summary judgment, the Crime Lab established,

through pleadings, Williams’s affidavit, records, and subsequent testimony, a prima facie case

that there were no material issues of fact in dispute. The Crime Lab had complied with

section 12-12-312(a)(1)(A)(i) and (ii). It produced all records that were required and did not

produce those that were prohibited. Once the burden shifted, Williamson could not identify

any missing records he was entitled to and thus could not meet his burden to demonstrate

the existence of material disputed facts. Once the moving party establishes its prima facie

case, the opposing party must meet proof with proof. Williamson failed. It follows, then,

that Williamson has failed to demonstrate a clear and certain right to the issuance of a writ

of mandamus. Scott, 2025 Ark. 152, 720 S.W.3d 865. We find the circuit court did not err

in granting summary judgment, and we affirm.

Affirmed.

WOMACK, J., dissents.

SHAWN A. WOMACK, Justice, dissenting. Dismissal of the case is proper pursuant

to article 5, section 20 of the Arkansas Constitution. 1 Absent an express constitutional

provision to the contrary, the State can never properly be a defendant in any of its

courts.2 Here, Williamson improperly made the State a defendant when he petitioned for

1 See Thurston v. League of Women Voters of Ark., 2022 Ark. 32, at 17, 639 S.W.3d 319, 327 (Womack, J., dissenting). 2 Id.

4 mandamus and declaratory relief in a new civil action below, 60CV-24-2239.3 Instead, he

should have petitioned in his related, underlying criminal case. Accordingly, this court, like

the circuit court below, lacks jurisdiction. For these reasons, the circuit court’s order must

be reversed and the case dismissed.

Anthony Williamson, pro se appellant.

Tim Griffin, Att’y Gen., by: Chelsea Harvey, Ass’t Att’y Gen., for appellee.

3 See Perry v. Payne, 2022 Ark. 112, at 5 (Womack, J., dissenting) (reasoning Article 5, section 20 required the dismissal of the appeal from denial of writ of mandamus and declaratory judgment).