Ark. Dep't of Human Servs. v. Ledgerwood

Summary

The Arkansas Supreme Court dismissed as moot the Arkansas Department of Human Services' appeal concerning a permanent injunction against the 2015 ARChoices Medicaid waiver rule. The injunction had been dissolved after DHS promulgated a new rule that the circuit court found was properly promulgated under the Arkansas Administrative Procedure Act. The court declined to apply the exceptions to mootness for issues capable of repetition yet evading review or matters of substantial public interest.

Holdings

1. The appeal was moot because the permanent injunction no longer existed and no judgment by the Supreme Court could have a practical legal effect on an existing controversy.
2. Neither the capable-of-repetition-yet-evading-review exception nor the substantial-public-interest exception justified deciding the moot appeal.

Questions Presented

1. Whether the appeal became moot after DHS promulgated a new rule and the circuit court dissolved the permanent injunction.
2. Whether the appeal fell within the exceptions to mootness for matters capable of repetition yet evading review or matters of substantial public interest likely to be litigated in the future.

Disposition

dismissed