Roderick Talley v. State of Arkansas

2020 Ark. App. 461, 610 S.W.3d 164
CourtCourt of Appeals of Arkansas
DecidedOctober 7, 2020
StatusPublished
Cited by1 cases

This text of 2020 Ark. App. 461 (Roderick Talley v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roderick Talley v. State of Arkansas, 2020 Ark. App. 461, 610 S.W.3d 164 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 461 Reason: I attest to the accuracy and integrity of this document ARKANSAS COURT OF APPEALS Date: 2021-07-15 10:25:54 DIVISION II Foxit PhantomPDF Version: No. CR-20-134 9.7.5

OPINION DELIVERED: OCTOBER 7, 2020 RODERICK TALLEY APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, FOURTH DIVISION V. [NO. 60CR-16-271]

STATE OF ARKANSAS HONORABLE HERBERT THOMAS APPELLEE WRIGHT, JR., JUDGE AFFIRMED

ROBERT J. GLADWIN, Judge

Roderick Talley appeals the December 19, 2019 order of the Pulaski County Circuit

Court, which denied both his petition to seal a misdemeanor conviction and his motion to

strike the State’s response to the motion to compel. Talley argues on appeal that in so

ruling, the circuit court misinterpreted the Comprehensive Criminal Record Sealing Act

(“CCRSA”) of 2013, which is codified at Arkansas Code Annotated sections 16-90-1401

et seq. (Repl. 2016 & Supp. 2019). We affirm.

I. Procedural History

Talley was charged with second-degree battery on January 28, 2016. On September

19, he entered a negotiated guilty plea to second-degree assault, a Class B misdemeanor,

and he was ordered to pay a $500 fine. On April 19, 2018, Talley filed a pro se petition to

seal the misdemeanor conviction and claimed that he had completed all the requirements of

the conviction and had no pending felony charges in any state or federal court. On November 5, 2019, Talley filed an amended petition to seal his misdemeanor-

assault conviction and stated that he had one or more pending felony charges under Arkansas

Code Annotated as follows: section 5-54-111(b)(1) (second-degree escape); section 5-36-

103(b)(2)(A) (theft of property with value less than $25,000 but more than $5,000); section

5-13-211 (aggravated assault upon a law enforcement officer or employee of a correctional

facility); section 5-13-202 (second-degree battery); section 5-54-125 (fleeing); section 5-

54-125(c) (fleeing on foot); section 5-36-103(b)(4)(A) (theft of property); section 27-16-

303 (driving with an invalid license); and section 5-37-201 (forgery).

On December 6, Talley filed a motion to compel ruling on his petition to seal,

claiming that he had personally served a copy of his petition on the Pulaski County

Prosecuting Attorney’s Office on November 5. He alleged that pursuant to Arkansas Code

Annotated section 16-90-1413(b)(2)(A) (Supp. 2019), the prosecuting attorney may file a

notice of opposition to his petition to seal within thirty days from the date of filing.

Therefore, he claimed that when the State did not file any notice of opposition on or before

December 5, it waived any opposition to his petition to seal. He argued that section 16-

90-1413(b)(2)(B)(i) notes that when the State fails to file any notice of opposition, the circuit

court may grant the petition. He further cited section 16-90-1415(a) that “unless the circuit

court . . . is presented with and finds that there is clear and convincing evidence that

misdemeanor or violation conviction should not be sealed under this subchapter, the circuit

court . . . shall seal” the conviction. He argued that because the State did not file a notice

of opposition, the circuit court was not presented with clear and convincing evidence that

the conviction should not be sealed, and the statutes contain no other basis for a hearing on

2 the petition other than the State filing notice. See Ark. Code Ann. § 16-90-1413(b)(2)(B)(ii)

(if notice of opposition is filed, the court shall set the matter for a hearing). On the basis of

that argument, he claimed that the circuit court should grant his petition.

The State responded to Talley’s motion to compel on December 10 and alleged that

in Talley’s original petition to seal, he made false statements under oath by stating he had

no pending criminal cases when, in fact, he had two felony cases pending.1 The State argued

that because Talley had requested four continuances in the two cases, there still were no

resolutions to them. The State also claimed that on September 3, 2019, Talley was charged

with harassing communications and violating an order of protection, and the case was

pending in the Little Rock District Court; thus, the State was also waiting on a resolution

of this third criminal case before it filed its response.

The State argued that under section 16-90-1413(b)(2)(B), if the State does not file a

notice of opposition to a petition to seal a misdemeanor within thirty days, the court may

grant a petition to seal; however, there is no requirement that the court grant a petition to

seal if the State does not respond within thirty days. The State claimed that it did not believe

it could respond without knowing the resolution of the three pending criminal cases against

Talley. The State alleged that Talley’s own actions were the cause for the State’s delay in

filing written opposition to the petition to seal.

1 The State filed its response to Talley’s motion to compel ruling under two case numbers—60CR-15-3708 and 60CR-16-271. The circuit court granted the petition to seal in 60CR-15-3708, which dealt with charges the State had nolle prossed; thus, Talley is not appealing the court’s decision to seal the record in case number 60CR-15-3708. 3 On December 12, Talley filed a motion to strike the State’s “objection” as untimely.

He argued that the prosecution has only thirty days to file a notice of opposition to a petition

to seal a misdemeanor conviction. Ark. Code Ann. § 16-90-1413(b)(2)(A). He claimed

that because the State failed to file any notice of opposition on or before the thirtieth day,

December 5, the State waived any opposition to his petition. He argued that the State’s

response to his motion to compel ruling could only be construed as a written notice of

objection filed outside the thirty-day deadline. He urged the circuit court to look to the

substance of the pleading rather than the title, Mhoon v. State, 369 Ark. 134, 251 S.W.3d

244 (2007), and claimed that the State’s response is a late notice of objection to seal because

it accused Talley of lying under oath and noted that he had pending criminal cases.

II. Circuit Court Hearing and Order

At the December 18 hearing, the circuit court heard argument from counsel for both

parties. Regarding Talley’s motion to strike, he argued that regardless of the title of the

State’s response, the essence of the pleading is an objection, which was untimely and should

be struck under the statute. The circuit court denied the motion to strike the State’s

response to Talley’s motion to compel and did not make any findings regarding whether

the response was an “objection.”

Talley then argued that under the CCRSA, unless the circuit court is presented with

and finds clear and convincing evidence that a misdemeanor conviction should not be

sealed, the circuit court shall grant the petition to seal. He claimed that the State, having

not filed an objection, had not put on any evidence, “let alone enough to show by clear-

and-convincing evidence,” that the conviction should not be sealed. In response, the State

4 introduced exhibits 1–6, which are criminal records related to Talley’s 2018 and 2019

criminal charges and the sentencing order from 2016. Talley objected that “these are

untimely,” but the circuit court granted the State’s motion to admit the evidence. 2

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2020 Ark. App. 461, 610 S.W.3d 164, Counsel Stack Legal Research, https://law.counselstack.com/opinion/roderick-talley-v-state-of-arkansas-arkctapp-2020.