State of Arkansas v. Kentara Brown

2019 Ark. 395
CourtSupreme Court of Arkansas
DecidedDecember 12, 2019
StatusPublished
Cited by2 cases

This text of 2019 Ark. 395 (State of Arkansas v. Kentara Brown) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Arkansas v. Kentara Brown, 2019 Ark. 395 (Ark. 2019).

Opinion

Cite as 2019 Ark. 395 Digitally signed by Susan P. Williams SUPREME COURT OF ARKANSAS No. CR-18-860 Reason: I attest to the accuracy and integrity of this document Date: 2021.07.13 14:28:48 -05'00' Opinion Delivered December 12, 2019

STATE OF ARKANSAS APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, V. FOURTH DIVISION [NO. 60CR-09-1130] KENTARA BROWN APPELLEE HONORABLE HEBERT T. WRIGHT, JUDGE

REVERSED AND REMANDED.

SHAWN A. WOMACK, Associate Justice

The State of Arkansas appeals the circuit court’s order to expunge Kentara Brown’s

felony conviction under Act 531 of 1993. The State contends that Brown was ineligible for

expungement under the Act and that the circuit court’s order was erroneous as a matter of

law. We reverse and remand to set aside the order to expunge.

I.

Brown pleaded guilty to Class C felony theft of property in 2009. See Ark. Code

Ann. § 5-36-103 (Repl. 2006). She was sentenced to three years of probation. The State

conceded that Brown was initially placed on probation under Act 531, also known as the

Community Punishment Act. See Ark. Code Ann. §§ 16-93-1201 to -1210 (Repl. 2006).

The original judgment and disposition order left unmarked a blank next to the statement:

“Defendant committed a target offense and was sentenced under the Community

Punishment [A]ct. Upon successful completion of the conditions of probation/S.I.S. Defendant shall be eligible to have [her] records sealed.” The conditions of probation,

however, referenced Act 531.

In 2011, the State petitioned to revoke the original order after Brown failed to

comply with the conditions of probation. She pleaded guilty to the revocation charge. The

circuit court entered a new judgment and disposition order resentencing Brown to four

years of probation for the theft-of-property conviction. Like the original order, the new

order included a blank next to a statement indicating whether the sentence was under Act

531 and eligible for expungement. This time, the circuit court wrote “no” in the blank.

The new conditions of probation likewise omitted any reference to the Act.

In 2018, Brown petitioned to expunge her conviction under Act 531. The State

objected. It argued that revocation of the original order meant that she failed to successfully

complete probation under the Act. Because the post-revocation order was explicitly not

under Act 531, the State argued Brown was ineligible for expungement under either order.

The circuit court granted Brown’s petition to expunge her conviction under Act

531. An order to expunge was subsequently entered. In the order, the court concluded that

Brown had been sentenced under Act 531 and that she had “satisfactorily complied” with

the court’s orders. It referenced only the original three-year probation order. The post-

revocation order was not mentioned. It is from this decision that the State appeals.

II.

For its sole point on appeal, the State contends that the circuit court erroneously

expunged Brown’s conviction under Act 531. In short, the State argues that Brown failed

to successfully complete an order of probation under Act 531 and is thus ineligible for

2 expungement under the Act’s provisions. This argument is twofold. First, the State claims

that Brown did not successfully complete the original probation order due to its revocation.1

The State also contends that the post-revocation probation order was not under Act 531

and may not be expunged under the Act.

Though we must typically consider the propriety of the State’s appeal under Arkansas

Rule of Appellate Procedure–Criminal 3, we need not do so here. We have consistently

held that an appeal from an order to seal a conviction, despite its criminal designation, is

civil in nature and not subject to Rule 3. See State v. Tyler, 2010 Ark. 307, at 2. We thus

accept this appeal without engaging in a Rule 3 analysis.

It is well settled that a sentence must be in accordance with the statutes in effect on

the date of the crime. See id. A court does not have the power to expunge a record when

the defendant was not sentenced under a statute that specifically provides for expungement.

See id. Moreover, a court may expunge a record only when the facts of the defendant’s case

meet the requirements outlined by the legislature in the expungement statute. See Bolin v.

State, 2015 Ark. 149, at 8, 459 S.W.3d 788, 793. Resolution of this matter accordingly turns

on the application and interpretation of Act 531. The question of the correct application

and interpretation of an Arkansas statute is a question of law, which this court decides de

novo. See id. at 4, 459 S.W.3d at 791.

We must begin with the statute. Act 531, in relevant part, provides that:

(a) Upon the sentencing or placing on probation of any person under the provisions of this subchapter, the sentencing court shall issue an order . . . in writing, setting forth the following: 1 We reject Brown’s contention that the State failed to preserve this argument. The record establishes that the argument was raised during the hearing on the petition.

3 (1) That the offender is being: ....

(D) Placed on probation under the provisions of this subchapter[.]

....

(b)(1) Upon the successful completion of probation . . . for one of the offenses targeted by the General Assembly for community correction placement, the court may direct that the record of the offender be expunged of the offense for which the offender was either convicted or placed on probation under the condition that the offender has no more than one previous felony conviction[.]

Ark. Code Ann. § 16-93-1207. In other words, the circuit court has the authority to

expunge an offender’s record if the offender (1) has successfully completed a sentence under

Act 137, (2) for a target offense, and (3) has no more than one previous felony conviction,

provided the previous conviction is not among the enumerated list of disqualifying felonies.

See Fulmer v. State, 337 Ark. 177, 181, 987 S.W.2d 700, 701 (1999). The parties do not

dispute Brown’s satisfaction of the latter two requirements. The dispositive question is,

therefore, whether Brown successfully completed a sentence under the Act.

We first consider the original judgment and disposition order, which placed Brown

on probation for three years. The State conceded below—and the circuit court agreed—

that the original order was under Act 531. Even assuming this concession was correct,

Brown is eligible for expungement only upon successful completion of that sentence. Given

that the original order was revoked in 2011, the State contends that Brown did not

successfully complete probation under that order. We agree.

Once Brown violated the terms of probation, the circuit court was authorized to

revoke her sentence and impose any sentence that may have been originally imposed for

4 the conviction. See Ark. Code Ann. § 5-4-309(f) (Repl. 2006); see also Lee v. State, 2010

Ark. 261, at 3 (per curiam). That is precisely what happened. Following revocation, the

circuit court entered a new judgment and disposition order resentencing Brown to four

years of probation for the theft-of-property conviction. Brown accordingly failed to

successfully complete probation under the revoked order. Her eligibility for expungement

under Act 531 must therefore be determined under the post-revocation order. To the extent

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