Justia Arkansas Supreme Court Opinion Summaries

Articles Posted in Education Law
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The Supreme Court reversed the order of the circuit court granting a temporary restraining order (TRO) in favor of Plaintiffs in their lawsuit challenging the validity of the emergency clause in Act 237 of 2023 (the LEARNS Act), holding that the circuit court erred in granting Plaintiffs' motion for injunctive relief.After the LEARNS Act was signed into law Plaintiffs sought a TRO, asserting that they would suffer irreparable harm if Defendants continued to implement the Act despite an invalid emergency clause relating to the creation of transformation contracts. The circuit court granted the TRO until a scheduled hearing. The Supreme Court reversed and vacated the TRO, holding that Plaintiffs failed to meet their burden of providing irreparable harm. View "Ark. Dep't of Education v. Jackson" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying the motion to dismiss this action against the Arkansas Department of Education, members of the Arkansas State Board of Education, and the Commissioner of Education (collectively, the State Board), holding that the circuit court correctly denied sovereign immunity on the constitutional delegation of authority claim.Several parents and grandparents of students in the Little Rock School District brought this lawsuit challenging the State Board's continued control of LRSD through limitations placed on a new school board. The State Board filed a motion to dismiss based on sovereign immunity and lack of subject matter jurisdiction. The circuit court denied the motion to dismiss. The Supreme Court affirmed in part and reversed in part, holding (1) the circuit court lacked subject matter jurisdiction over Plaintiffs' Administrative Procedure Act claim; (2) Plaintiffs failed to sufficiently plead an illegal-acts or ultra vires exception to sovereign immunity under Ark. Code Ann. 6-15-2917(c); and (3) the circuit court properly denied sovereign immunity on Plaintiffs' constitutional delegation of authority claim because the sufficiently pled challenge to the constitutionality of Ark. Code Ann. 6-15-2916 and -2917 overcame sovereign immunity. View "Arkansas Department of Education v. McCoy" on Justia Law

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The Supreme Court affirmed the circuit court’s denial of Appellant’s petition for writ of mandamus alleging that his rights had been violated by the denial of his parole. The circuit court found, among other things, that Appellant failed to establish that he had a right to be paroled, that the Due Process Clause does not create a protected liberty interest for an inmate to have a specific release and parole-eligibility date, and that the denial of Appellant's parole was not a new punishment in violation of double jeopardy. In affirming, the Supreme Court held that Appellant failed to establish a right or a performance of a duty for which the writ should issue. View "Warren v. Felts" on Justia Law

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In 2014, the Arkansas State Board of Education (State Board) classified six schools within the Little Rock School District as being in academic distress. In 2015, the State Board voted to immediately remove all members of the District’s board of directors and to direct the commissioner of education to assume the authority of the Board of Directors for the governance of the District. Appellees, three former members of the District board of directors and a parent whose children attend school in the District - filed an amended complaint for declaratory relief, writ of prohibition, writ of mandamus, and injunctive relief, alleging that the State Board’s actions were unconstitutional, ultra vires, arbitrary, capricious, and wantonly injurious. Appellants moved to dismiss the complaint, arguing that the action was barred by sovereign immunity. The trial court denied the motion to dismiss. Appellant subsequently filed this interlocutory appeal. The Supreme Court reversed and dismissed Appellees’ complaint, holding (1) the allegations in the complaint did not establish a sovereign-immunity exception; but (2) Appellees failed to establish in their complaint that the State Board acted arbitrarily, capriciously, or in bad faith in assuming control of the District. View "Key v. Curry" on Justia Law

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Two School Districts filed suit against the Arkansas Department of Education (ADE) asking for a mandatory injunction requiring the ADE to release all federal and state funds that they were due. The circuit court granted partial summary judgment for the School Districts. The School Districts subsequently moved to have the ADE found in contempt due to the ADE’s refusal to release all amounts they alleged they were due. The circuit court declined to hold the ADE in contempt. The School Districts appealed, and the Supreme Court remanded the case. On remand, the School Districts filed a motion requesting that the circuit court order the ADE to release to them ninety-eight percent guaranteed Uniform Rate of Tax (URT) adjustment funds that had been released by the ADE in all prior school years and which the ADE had illegally “set off” against “excess URT funds” for certain school years. The circuit court denied relief. The School Districts appealed. The Supreme Court affirmed, holding that the first appeal did not address the issue of the ninety-eight percent guaranteed URT adjustment funding, and therefore, the circuit court did not err in finding that it lacked the authority to order that those funds be disbursed by the ADE. View "Furnas v. Kimbrell" on Justia Law

Posted in: Education Law
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Deer/Mt. Judea School District (“Deer/Mt. Judea”) filed a complaint on its own behalf and on behalf of its students and taxpayers, alleging that the State had illegally and unconstitutionally failed to provide adequate funding to small, remote schools, some of which it closed. Deer/Mt. Judea sought declarations that the State’s school-funding and education systems were inequitable and inadequate and that section 32 of Act 293 of 2010 constituted special legislation and injunctions prohibiting the closure of the small, remote schools, among other things. The Supreme Court reversed the circuit court’s dismissal of some of Deer/Mt. Judea’s claims. Fort Smith School District, Greenwood School District, Alma School District, and Van Buren School District (collectively, “Fort Smith”) filed a motion to intervene in the litigation. The circuit court denied the motion, concluding that Fort Smith’s motion was untimely, and even if it was timely, Fort Smith did not have an interest in the case that needed to be protected. The Supreme Court affirmed the denial of the motion to intervene, holding that the circuit court did not abuse its discretion in denying the motion for intervention as untimely. View "Fort Smith Sch. Dist. v. Deer-Mt. Judea Sch. Dist." on Justia Law

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Anita Cooper, who was employed as principal of the Oark, Arkansas schools, was removed from her duties as principal. The Superintendent of the Jasper School District No. 1 of Newton County listed nine reasons as bases for the termination. The District’s Board of Directors then terminated Cooper’s employment. The circuit court reversed the Board’s decision, reinstated Cooper to her position, and awarded Cooper $64,998 in damages. The Superintendent and District appealed. The Supreme Court affirmed, holding (1) the circuit court did not err in finding that Defendants failed to comply with the Teacher Fair Dismissal Act; (2) the circuit court did not err in concluding that the contract in the case at bar created a property right in Cooper’s position as principal of the Oark schools; and (3) the circuit court’s award to Cooper was neither excessive nor amounted to an award of “double retirement.” View "Jasper Sch. Dist. No. 1 v. Cooper" on Justia Law

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In this school-funding dispute, a school district (District) filed an action on its own behalf and on behalf of its taxpayers to enjoin state actions in violation of state law and the Arkansas Constitution. The District alleged two claims against Appellees. The District then voluntarily nonsuited the special-and-local legislation claim so it could immediately appeal the adequacy claim in the "Beebe" case. The District brought the special-and-local-legislation claim as a separate case in the "Kimbrell" case. The Supreme Court dismissed the appeal of the Beebe case for a lack of finality. The circuit court subsequently consolidated the Beebe case and the Kimbrell case. After the circuit court decided the cases, the District appealed. The Supreme Court affirmed in part, reversed and remanded in part, and mooted in part, holding (1) the circuit court abused its discretion in ruling that some of the District's claims in the Beebe case were barred by res judicata but did not err in dismissing the District's other claims as barred by res judicata; (2) the circuit court did not err in striking the District's amended and supplemental complaint; and (3) the District's claims in the Kimbrell case were moot. View "Deer-Mt. Judea Sch. Dist. v. Kimbrell" on Justia Law

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Appellants filed four separate cases stemming from the Arkansas Department of Education's (ADE) administrative supervision of the Pulaski County Special School District (PCSSD) after the district was found to be in fiscal distress. In each of the cases, ADE filed a motion to dismiss, asserting that Appellants' claims for relief were barred by sovereign immunity because the complaints were brought against ADE regarding matters allegedly done in furtherance of ADE's official duties. The circuit court granted the motion in each of the four cases. Appellants appealed, asserting, inter alia, that the circuit court erred in dismissing ADE from their actions because the complaints alleged exceptions to the doctrine of sovereign immunity. The Supreme Court affirmed, holding that the circuit court did not err in granting ADE's motions to dismiss, as none of the recognized exceptions to the sovereign immunity doctrine applied in these cases. View "Fitzgiven v. Dorey" on Justia Law

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In 2010, voters in the Fayetteville School District approved a 2.75 new-debt-service mills that would be a continuing debt service tax until the retirement of proposed bonds to be issued for the purpose of erecting and maintaining new and existing school facilities. The surplus revenues produced by debt service millage would be used for other school purposes. In 2011, certificates issued by the Washington County tax collector resulted in 1.45 mills of that 2.75-mill ad valorem increase being applied to the retirement of redevelopment-district bonds issued in 2005. The School District sought declaratory judgment and injunctive relief. The circuit court found that the assessor's certification was incorrect and that the tax collector improperly applied the 1.45 mills. The Supreme Court affirmed, holding (1) the present cause of action was not barred by res judicata; (2) Ark. Code Ann. 14-168-301(18)(B)(i) did not impair the bond-purchase contract and financing of the redevelopment bonds; and (3) the 2.75 expressly pledged the new millage to a bond in accordance with section 14-168-301(18)(B)(i). View "City of Fayetteville v. Fayetteville Sch. Dist. No. 1" on Justia Law