Supreme Court of Arkansas

State of Arkansas v. Jeremy Lynn O'Quinn

May 23, 20132013 Ark. LEXIS 256

Summary

The court held that the State could appeal because the case involved the uniform administration of statutory sentencing law and an allegedly illegal sentence. Because O’Quinn was sentenced as a habitual offender for a Class Y felony, the circuit court was required to impose at least ten years’ imprisonment and could not suspend that required term. The court rejected the State’s argument that a fine was mandatory because the applicable statute authorized a fine of up to $25,000 without prescribing a minimum. Chief Justice Hannah and Justices Baker and Hart, dissenting, would have rejected the majority’s treatment of the offense as a Class Y felony for disposition purposes, and Justice Hart also criticized the failure to address the underlying sentencing range for manufacturing methamphetamine.