Justia Education Law 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

The Arkansas School for the Deaf's Board of Trustees terminated Appellant Darleen Tripcony from her employment with the School as part of a reduction in force (RIF). The Arkansas State Employee Grievance Appeal Panel (SEGAP) upheld the Board's RIF of Tripcony's position. Tripcony subsequently filed a complaint in circuit court requesting judicial review of the decision by SEGAP upholding the denial of her appeal and further sought declaratory and injunctive relief against the School. The circuit court dismissed the complaint on the basis that it lacked subject-matter jurisdiction and that Tripcony's claim against the School's Board of Trustees was barred by the doctrine of sovereign immunity. The court also dismissed Tripcony's claims against several members of the Board in their individual capacities based on the doctrine of sovereign immunity. The Supreme Court affirmed, holding (1) the circuit court lacked subject-matter jurisdiction to conduct a judicial review of the termination of a state employee; and (2) it necessarily followed that the Court also lacked jurisdiction to decide the appeal issues relating to the immunity issues. View "Tripcony v. Ark. Sch. for the Deaf" on Justia Law

Appellant school district filed an action on its own behalf and on behalf of its students and taxpayers to enjoin State actions in violation of state law and the Arkansas Constitution, asserting two claims for relief. The circuit court granted Appellant's motion to dismiss its second claim without prejudice. The court then entered an order dismissing Appellant's claims against all Appellees. Appellant appealed. The Supreme Court dismissed the appeal without prejudice, holding that the order from which Appellant appealed was not a final, appealable order, as the nonsuit of Appellant's second claim did not operate to make the circuit court's order final because the second claim could be refiled and the requirements of Ark. R. Civ. P. 54(b) had not been met. View "Deer-Mt. Judea Sch. Dist. v. Beebe" on Justia Law

Brett Nelson entered into contracts with the Arkansas Rural Medical Practice Student Loan and Scholarship Board and the rural community Forrest City pursuant to the state's community-match program that loaned Nelson money for his medical schooling and obliged him to practice medicine full time in Forrest City for four years upon the completion of his residency. Nelson began serving his four-year commitment in Forrest City, but when the hospital he was employed with did not renew his employment contract the next year, Nelson left Forest City to practice medicine in another state. The Board filed a complaint against Nelson for breach of contract and, alternatively, unjust enrichment. Nelson answered, asserting several affirmative defenses and making several counterclaims. The circuit court granted the Board's motion for summary judgment and entered judgment against Nelson in the amount of $133,152. The Supreme Court (1) reversed the grant of summary judgment to the Board on its breach of contract claim because questions of fact remained as to Nelson's counterclaims and defenses; and (2) otherwise affirmed. Remanded. View "Nelson v. Ark. Rural Med. Practice Loan & Scholarship Bd." on Justia Law

The Harrisburg School District No. 6 and the Board of Education (the District) appealed an order from the circuit court that granted Appellee Byron Neal's motion for summary judgment. Mr. Neal was elected to one of five positions on the District's board of directors. His term did not expire until September, 2014. In February, 2010, the Weiner School District faced declining enrollment, and as a result, the Harrisburg and Weiner Districts entered into an agreement for an administrative annexation of the two districts. Mr. Neal was present at the February, 2010 meeting of the Harrisburg board of directors and voted in favor of the annexation. In March, an interim school board was formed from the annexed districts. The Harrisburg District chose its interim board members by selecting four of its five members to serve. Mr. Neal lost his position. In June, Mr. Neal filed his complaint with the circuit court to stop the District from removing him as a board member. On appeal to the Supreme Court, the District argued that state law gave it the authority to agree on how the board of directors would be staffed, and therefore the circuit court erred in granting Mr. Neal summary judgment. The Supreme Court found no error by the circuit court and affirmed the grant of summary judgment to Mr. Neal.