Justia Arkansas Supreme Court Opinion Summaries

The case involves Little Scholars of Arkansas, AP Consolidated Theatres II L.P., CSRC Charter LISA, LLC, and KLS Leasing LLC (collectively, appellants) who appealed against Pulaski County, Arkansas, and its officials (collectively, appellees). The appellants operate charter schools and lease properties for their schools. The appellees assessed real-property taxes against the schools, which the appellants contested, arguing that the properties used for school purposes are exempt from taxes under the Arkansas Constitution. The appellants also sought a declaration that Ark. Code Ann. § 6-21-118, which they claimed the appellees relied on for the tax assessment, is void under the constitution.The case was initially brought before the Pulaski County Circuit Court. The appellees moved to dismiss the case, arguing that the county courts have exclusive jurisdiction over county tax matters. The circuit court agreed with the appellees, dismissing the case on the grounds that it lacked subject-matter jurisdiction over the appellants' claims.The case was then brought before the Supreme Court of Arkansas. The appellants argued that the circuit court did have subject-matter jurisdiction over their illegal-exaction claims. They also argued that their request for a declaration that Ark. Code Ann. § 6-21-118 is void does not fall within the county court’s jurisdiction. The Supreme Court disagreed with the appellants, affirming the circuit court's decision. The Supreme Court held that the appellants' claim was not an illegal-exaction claim but an assessment dispute, which falls within the exclusive original jurisdiction of the county court. The Supreme Court also held that the circuit court did not have subject-matter jurisdiction over the appellants' request for declaratory judgment. View "LITTLE SCHOLARS OF ARKANSAS FOUNDATION v. PULASKI COUNTY, ARKANSAS" on Justia Law

The case revolves around Chris Corbitt, a holder of an Enhanced Concealed Carry License (ECCL), who filed a complaint for declaratory judgment and injunctive relief against Arkansas State University (ASU) and its trustees. Corbitt sought a declaration that he was entitled to enter the First National Bank Arena (FNB Arena), located on ASU's campus, with a firearm, except for areas hosting a collegiate sporting event. He also sought an order enjoining ASU from prohibiting ECCL holders from entering FNB Arena with a firearm. The FNB Arena is covered by an Alcoholic Beverage Control (ABC) permit, held by NEA Sports Club, which authorizes the consumption and sale of beer and wine on the premises during designated events.The Craighead County Circuit Court granted ASU's motion for summary judgment. The court found that under Arkansas law, FNB Arena can be covered by an ABC permit and ASU can lawfully prohibit firearms in FNB Arena to maintain the alcohol permit while complying with Ark. Code Ann. § 5-73-306(11)(B) as well as Title 3 permit requirements and ABC regulations.The Supreme Court of Arkansas affirmed the lower court's decision. The court held that ASU can lawfully prohibit firearms at FNB Arena under section 5-73-306. The court reasoned that while universities do not have the discretion to prohibit firearms, ASU is prohibiting firearms at FNB Arena because the facility is covered by an alcohol permit, not because it is attempting to exercise discretion. The court concluded that the unambiguous language of subdivision (11)(B) supports ASU’s position that an ECCL holder may not enter FNB Arena with a firearm. View "CORBETT V. ARKANSAS STATE UNIVERSITY" on Justia Law

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

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

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

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

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

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

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

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