Justia Arkansas Supreme Court Opinion Summaries

The Supreme Court mooted in part and reversed and remanded in part the decision of the circuit court dismissing Monsanto Company's amended complaint against the Arkansas State Plant Board and its members (collectively, the Plant Board) on the basis of sovereign immunity, holding that portions of this matter were moot and, as to the remainder, sovereign immunity was inapplicable.In 2017, the Plant Board promulgated a rule that would prohibit in-crop use of dicamba herbicides during the 2018 growing season. Monsanto filed a complaint setting forth seven alleged claims against the Plant Board. Each of Monsanto's claims sought injunctive or declaratory relief for alleged illegal or unconstitutional activity by the Plant Board and did not seek an award of monetary damages in any respect. The circuit court granted the Plant Board's motion to dismiss based on sovereign immunity. The Supreme Court reversed, holding (1) the portions of the complaint that relate exclusively to the 2016 and 2017 promulgations were moot because the Plant Board has since promulgated a new set of regulations on pesticide use; and (2) Monsanto's claims were sufficiently developed as to properly allege ultra vires conduct, and under the circumstances, the Plant Board must address the merits of Monsanto's claims. View "Montsanto Co. v. Arkansas State Plant Board" on Justia Law

The Supreme Court affirmed the order of the circuit court granting a motion to dismiss filed by the Arkansas State Highway Commission and the Arkansas Department of Transportation and its director in this challenge to a contract entered into between the Department and the United States Fish and Wildlife Service (USFWS), holding that the circuit court correctly found that the complaint failed to state facts upon which relief could be granted.Under the contract in this case the Department would cede certain property to USFWS in exchange for a fifty-acre easement over land in the Cache River and White River Wildlife Refuges in order to build a new bridge on Highway 79. The agreement further required the Department to convey additional land to USFWS and to demolish three bridges. Appellants filed a motion for preliminary injunction and complaint for declaratory and injunctive relief, arguing that the contract was unconscionable, entered into under duress, and constituted a windfall to USFWS. The circuit court dismissed the complaint. The Supreme Court affirmed, holding that the complaint lacked sufficient facts to state a claim for an illegal exaction. View "Prince v. Arkansas State Highway Commission" on Justia Law

The Supreme Court dismissed as moot the appeal brought by Appellants, the Arkansas State Plant Board and its director, challenging the circuit court's temporary restraining order (TRO) that enjoined the Plant Board from enforcing its agency rule limiting the use of dicamba herbicides after April 15, 2018, holding that because Appellants had since repealed and replaced this rule, the appeal was moot.While Appellants' appeal was pending, the Plant Board repealed and replaced the rule. The Supreme Court held that because the judgment on this appeal would have no practical legal effect on the TRO's enforceability, this interlocutory appeal is dismissed as moot. View "Arkansas State Plant Board v. Stephens" on Justia Law

In this companion case to Arkansas State Plant Board v. Bell, __ S.W.3d __, which the Court handed down on May 23, 2019, the Supreme Court dismissed the appeal from the circuit court's temporary restraining order (TRO) that enjoined the Arkansas State Plant Board and its officers and members (collectively, the Plant Board) from enforcing its agency rule limiting the use of dicamba herbicides after April 15, 2018, holding that because the Plant Board had since repealed and replaced the rule and the TRO had expired by operation of law, the appeal was moot. View "Arkansas State Plant Board v. Johnson" on Justia Law

The Supreme Court dismissed as moot Appellants' appeal of the circuit court's temporary restraining order (TRO) that enjoined the Arkansas State Plant Board from enforcing its agency rule limiting the use of dicamba herbicides after April 16, 2018, holding that the appeal was moot.On April 16, 2018, thirty-seven Arkansas farmers who intended to use dicaamba herbicides in 2018 (Appellees), filed a complaint against the Plant Board seeking a declaratory judgment and injunctive relief. The circuit court granted a TRO and enjoined the Plant Board from enforcing its April 15 cutoff date. The Plant Board appealed. On February 27, 2019, the Plant Board promulgated a new rule that repealed the April 15 cutoff date and took effect beginning March 9, 2019. The Supreme Court dismissed the interlocutory appeal as moot, holding that judgment on this appeal would have no practical effect upon the TRO's enforceability. View "Arkansas State Plant Board v. Bell" on Justia Law

The Supreme Court affirmed the decision of the Arkansas Workers' Compensation Commission adopting the finding of an administrative law judge (ALJ) that Appellant's additional benefits claim was barred by the statute of limitations, holding that the Commission did not err in finding that Appellant's claim was barred by the statute of limitations.After a hearing, the ALJ found that Appellant's claim was barred by the statute of limitations. The Commission affirmed and adopted the ALJ's findings. The court of appeals reversed, concluding that the statute of limitations had tolled. The Supreme Court vacated the opinion of the court of appeals and affirmed the Commission's finding, holding that the Commission's decision was supported by substantial evidence. View "Farris v. Express Services, Inc." on Justia Law

The Supreme Court reversed the circuit court's order holding the Arkansas Department of Human Services (DHS) in contempt but dismissed DHS's appeal of a temporary restraining order enjoining its emergency rule, holding that DHS did not violate the express terms of the circuit court's preliminary injunction order by promulgating the emergency rule and that the appeal from the temporary restraining order was moot.The Supreme Court previously upheld the circuit court's temporary restraining order enjoining the 2015 ARChoices Medicaid waiver rule as applied to the named plaintiffs. On remand, the circuit court entered a permanent injunction against the program, and DHS was permanently enjoined from using the methodology embraced by that rule unless it was "properly promulgated." Thereafter, DHS promulgated an emergency rule utilizing the same methodology. The circuit court entered a temporary restraining order against the rule and held DHS in contempt of its permanent injunction order, concluding that DHS failed to provide notice and an opportunity for public comment during the adoption of the emergency rule. The Supreme Court disagreed, holding (1) the emergency rule was properly promulgated under the Administrative Procedure Act's emergency rule making provision; and (2) therefore, DHS did not violate the express terms of the circuit court's permanent injunction order when adopting the emergency rule. View "Arkansas Department of Human Services v. Ledgerwood" on Justia Law

The Supreme Court affirmed the circuit court’s dismissal of Appellant’s petition for judicial review under the Arkansas Administrative Procedure, declaratory relief, and petition for writ of mandamus, holding that the circuit court did not err in denying relief.In his petition, Appellant challenged the decision of the Arkansas Board of Parole denying him parole for an additional year. The circuit court held that Appellant failed to state a claim establishing a constitutional violation that would allow for judicial review or injunctive relief. The court denied the petition for writ of mandamus, concluding that the Board’s decision was discretionary. The Supreme Court affirmed, holding that the circuit court (1) did not abuse its discretion in finding that Appellant’s speculative claim could not survive a motion to dismiss; and (2) did not err in denying the writ of mandamus. View "Null v. Arkansas Parole Board" on Justia Law

The Supreme Court reversed the order of the circuit court dismissing with prejudice this administrative appeal from final orders of the Arkansas Oil and Gas Commission (AOGC), holding that the circuit court erred in concluding that the doctrine of sovereign immunity barred its consideration of the petition for review of the AOGC orders.In addition to dismissing the administrative appeal, the circuit court declared the adjudicatory provisions of the Arkansas Administrative Procedure Act (APA) unconstitutional and declared the AOGC orders at issue void ab initio. The Supreme Court reversed the circuit court’s order in its entirety, holding (1) sovereign immunity was not implicated in this case because the role of the AOGC was that of a quasi-judicial forum and the AOGC was not “made defendant” within the meaning of Ark. Const. art. V, 20; and (2) because the circuit court erred in concluding that sovereign immunity applied to bar its consideration of the petition for review of the AOGC orders, the rulings declaring the adjudicatory provision of the APA unconstitutional and the AOGC’s orders void ab initio must also be reversed. View "Arkansas Oil & Gas Commission v. Hurd" on Justia Law

The Supreme Court reversed and remanded this case to the Workers’ Compensation Commission for further proceedings, holding that the evidence indicating that Deputy Cleon Morgan was an independent contractor and, therefore, there was not substantial evidence to support the Commission’s decision that Morgan was an employee at the time of his injury.The Commission found that, at the time of his injury, Deputy Morgan had two employers, the Jefferson County Sheriff’s Department and Brookshire Grocery Company. The Commission concluded that both were liable for Deputy Morgan’s workers’ compensation benefits as “joint employers.” Brookshire appealed. The Supreme Court reversed the Commission’s decision, holding that where all the factors that are to be considered in determining if Deputy Morgan was an employee or an independent contractor indicate that Deputy Morgan was an independent contractor, the case must be remanded for further proceedings for a determination as to whether Brookshire was indeed liable for workers’ compensation benefits. View "Brookshire Grocery Co. v. Morgan" on Justia Law