Arkansas Department of Finance & Administration v. 2600 Holdings, LLC

Summary

The Supreme Court of Arkansas held that sovereign immunity did not bar 2600 Holdings’ petition for a writ of mandamus, although whether mandamus was warranted remained a merits issue outside the interlocutory appeal. The court dismissed the company’s declaratory-relief claim because it failed to allege that the State acted illegally, unconstitutionally, or ultra vires, and dismissed claims seeking relief under the Administrative Procedure Act for lack of subject-matter jurisdiction. The court affirmed in part, dismissed in part, and remanded.

Holdings

1. Sovereign immunity does not preclude a petition for a writ of mandamus because the Arkansas Constitution and implementing statutes vest circuit courts with subject-matter jurisdiction to issue writs of mandamus.
2. The declaratory-relief claim was barred by sovereign immunity because the complaint did not plead that the State's actions were illegal, unconstitutional, or ultra vires.
3. To the extent 2600 Holdings sought relief under the Arkansas Administrative Procedure Act, the case had to be dismissed for lack of subject-matter jurisdiction because the challenged licensing decision was not a reviewable agency adjudication.

Questions Presented

1. Whether sovereign immunity barred 2600 Holdings's petition for a writ of mandamus against the State agencies.
2. Whether sovereign immunity barred 2600 Holdings's claim for declaratory relief.
3. Whether, to the extent 2600 Holdings sought relief under the Arkansas Administrative Procedure Act, the circuit court had subject-matter jurisdiction to review the licensing decisions.

Disposition

other