Jason Carroll Neal, Appellant v. State of Arkansas, Appellee

Summary

The court held that Neal’s due-process claim was cognizable in a Rule 37 proceeding and that his advance waiver of due process was ineffective because he could not knowingly waive the opportunity to contest unknown future allegations. Because Neal was expelled from the drug-court program and sentenced without a meaningful hearing, the court reversed, vacated the sentencing order, and remanded for a hearing. Justice Goodson concurred to identify additional procedural deficiencies, while Justice Wood, joined by the Chief Justice and Justice Danielson, would have affirmed because Neal admitted violating a residential-program condition and had already received the necessary hearing.