Cite as 2016 Ark. 157
the separation-of-powers doctrine. Rule 402, however, is procedural in that it dictates what evidence is relevant. Just as we will not interpret a statutory provision so as to reach an absurd result, neither will we interpret a court rule in such a manner. Jonesboro Healthcare Ctr., LLC v. Eaton-Moery Envtl. Servs., Inc., 2011 Ark. 501, 385 S.W.3d 797. If we were to grant authority to the legislature to determine the relevancy of evidence in court proceedings, we would be depriving the trial courts of their exclusive authority to determine the relevancy of evidence. Such an interpretation of Rule 402 would create an absurd result.[1]
Prior to the passage of amendment 80, this court and the legislature shared authority to prescribe procedure. Curtis v. State, 301 Ark. 208, 783 S.W.2d 47 (1990). In State v. Sypult, 304 Ark. 5, 7, 800 S.W.2d 402, 404 (1990), we held that when conflicts arise between legislation and rules of evidence and procedure, "our rules remain supreme." Conversely, since the passage of amendment 80, we held that "so long as a legislative provision dictates procedure, that provision need not directly conflict with our procedural rules to be unconstitutional. This is because rules regarding pleading, practice, and procedure are solely the responsibility of this court." Johnson, 2009 Ark. 241, at 8, 308 S.W.3d at 141.
The seat-belt statute is procedural and therefore offends the principle of separation of powers and the powers specifically prescribed to this court by amendment 80. See Johnson. Accordingly, we hold that Arkansas Code Annotated section 27-37-703 violates separation
- ↑ We request our Civil Practice Committee to review Rule 402 in light of this opinion. To the extent that any other rules of evidence conflict with Johnson v. Rockwell, we refer those rules to the Committee for review as well.
9
