MacKool v. State
2012 Ark. 287
| Ark. | 2012Background
- Appellant Michael R. MacKool was convicted of first-degree murder and theft, receiving a cumulative 60-year sentence.
- In September 2010, appellant’s mother deposited $1,000 into his inmate account, bringing the balance to over $5,000.
- In October 2010, the State filed a petition under the Inmate Reimbursement Act to recover costs of care from appellant’s account.
- A show-cause hearing was held; the circuit court awarded $50,016.61 to the State and ordered it deposited to the state treasury.
- Appellant challenged the ruling on multiple statutory and procedural grounds; the circuit court’s order was affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether notice timing violated due-process or equal-protection rights | MacKool | State | No relief; issue waived for failure to raise below |
| Whether gifts from a living parent fall within the statute's estate definition | MacKool | State | Gifts from mother are within estate under the statute; argument rejected |
| Whether the Attorney General's investigation requirement affected the outcome | MacKool | State | Not dispositive; had notice and opportunity to be heard; argument rejected |
| Whether the Inmate Reimbursement Act is facially neutral and rationally related to a legitimate government purpose | MacKool | State | Act is facially neutral with rational basis; justified by state cost recovery |
| Whether Burns v. State governs the relevance of estate definition and the circuit court’s reliance | MacKool | State | Burns applies; circuit court’s reliance not erroneous; Burns controls |
Key Cases Cited
- Burns v. State, 303 Ark. 64 (Ark. 1990) (estate includes any source whatsoever under the Act)
- Poff v. Peedin, 366 S.W.3d 347 (Ark. 2010) (clearly-erroneous standard for factual findings)
- Schultz v. Butterball, 402 S.W.3d 61 (Ark. 2012) (procedural rules for pro se appeals; preservation of arguments)
- Bethany v. Jones, 378 S.W.3d 731 (Ark. 2011) (statutory framework and due-process considerations)
- McLane S., Inc. v. Ark. Tobacco Control Bd., 375 S.W.3d 628 (Ark. 2010) (statutory interpretation and standard of review)
- Am. Trucking Ass’n v. Gray, 707 S.W.2d 759 (Ark. 1986) (equal-protection classifications require rational basis)