Arkansas v. Corbit (1998)
There are three cases that may be designated as Arkansas v. Corbit. The case discussed here is the 1998 Arkansas Supreme Court case concerning Randy Corbit, who was arrested for the possession and sale of marijuana, and the subsequent property forfeitures that he faced. Although the case originally appeared insignificant, it ultimately set a groundbreaking new precedent for appeal structure.
Randy Corbit, who lived in Phillips County, was under investigation by the First and Third Judicial Districts’ Drug Task Force and, specifically, by Michael Steele, who was a narcotics investigator. On the day of Corbit’s arrest, Steele sent two men, Christopher Jarrett and Edward Knapp, into the store where Corbit worked. These men were charged with the task of purchasing marijuana from Corbit with $100 of marked money that Steele had given them. When Jarrett and Knapp approached Corbit with the money, Corbit agreed to the sale and asked them to come back an hour later.
During the hour that Knapp and Jarrett waited, police officers watched as Corbit left the store, got in the 1987 GMC truck that was parked outside the store, and drove away, returning in approximately twenty minutes. Corbit retrieved an unknown item from the truck, went back into the store, and proceeded to sell Knapp and Jarrett twenty-three grams of marijuana when they returned.
Police then moved in to arrest Corbit. During the process of the arrest, the police found $1,810 in Corbit’s pocket, including the $100 of marked money. When the police seized the money, Lois Martin, the store owner, claimed that $1,710 was hers and that Corbit often kept the store’s money in his pockets in order to guard against theft. Furthermore, the police seized the truck in which Corbit had transported the drugs, though Norman Corbit, Randy Corbit’s father, claimed that the truck was his and that his son had used it for drug transportation without his knowledge or permission. The police also seized a number of weapons from a nearby trailer.
After the initial hearing, Norman and Randy Corbit filed a brief that further contested the forfeitures. The brief protested the forfeiture of the $1,710 in cash due to the fact that it belonged to the store where Corbit had worked, and it offered the weapons, as well as other items, as a replacement for the forfeiture of the truck. The court ruled that the sum of $1,710 dollars was still to be forfeited but accepted the exchange for the truck. It made its ruling contingent upon Corbit’s conviction of the drug charges.
Following this ruling, Norman and Randy Corbit filed an appeal that once again contested their property forfeitures. However, the Arkansas Supreme Court dismissed the appeal immediately in order to comply with Arkansas Rules of Appellate Procedure 2(a) and Arkansas Rules of Civil Procedure 54(b). Together, these rules state that until all judgments in a particular case are final, none of the judgments are eligible for appeal. Therefore, because the court’s ruling on Corbit’s brief was effective only if Corbit was convicted of the drug charges, the decision was not eligible for appeal. In this way, Arkansas v. Corbit set a legal precedent and reformed the process of appeals in multiple claim cases.
For additional information:
“Ark. R. Civ. P. 54.” Casetext.com. https://casetext.com/rule/arkansas-court-rules/arkansas-rules-of-civil-procedure/judgment/rule-54-judgments-costs (accessed February 7, 2022).
“Case No. 98-212: Corbit v. State. Supreme Court, Arkansas.” Justia.com. https://law.justia.com/cases/arkansas/supreme-court/1998/98-212.html (accessed February 7, 2022).
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