State of Arkansas, Appellant v. Jason Michael Johnson, Appellee

Summary

The court affirmed dismissal of the charges because Johnson entered an agreement not to prosecute, performed his part by obtaining the promised psychiatric evaluation, and detrimentally relied on the agreement by spending money and disclosing potentially incriminating information. The court held that detrimental reliance is required to enforce an agreement not to prosecute and that the circuit court did not clearly err in finding that requirement satisfied. Hannah, C.J., dissenting, would have dismissed the State's appeal because the issue was settled and would have treated detrimental reliance as irrelevant to enforcement of the agreement.