This case challenged the constitutionality of Arkansas postjudgment garnishment statutes (Ark. Stat. Ann. § 31-501 et seq.), under which a judgment creditor obtained a writ that led to garnishment of the plaintiff's wages without prior notice to her or an opportunity to claim exemptions, even though her wages were exempt under federal law. The plaintiff argued that the statutes violated due process by permitting seizure of exempt property without notice and a prompt hearing, and also conflicted with federal wage garnishment limits under the Supremacy Clause. The court granted summary judgment to the plaintiff, holding the statutes unconstitutional under the Fourteenth Amendment's Due Process Clause because they lacked required procedural safeguards such as notice of exemptions, an affidavit from the creditor, a bond, or a prompt hearing to contest erroneous seizures. The decision relied on Supreme Court precedents like Sniadach, Fuentes, Mitchell, and North Georgia Finishing, which require such protections in garnishment proceedings, while declining to reach the Supremacy Clause claim. The court enjoined further use of noncompliant writs and awarded the plaintiff the amount wrongfully garnished plus fees.
The case involved a plaintiff who opened investment accounts with the defendants and later alleged violations of the Securities Exchange Act of 1934 and RICO due to fraudulent transactions depleting the accounts. The defendants moved to stay the proceedings and compel arbitration pursuant to arbitration clauses in the account agreements under the Federal Arbitration Act. The court granted the motion, holding that both the securities and RICO claims were subject to arbitration because the agreements were valid, there was no waiver by defendants, and Congress had not indicated an intent to exempt these claims from arbitration unlike certain 1933 Act claims.
The case involved Southwestern Bell Telephone Company seeking declaratory and injunctive relief against the Arkansas Public Service Commission for allegedly failing to follow FCC orders and rules on accelerated depreciation methods and cost allocation procedures when setting intrastate telephone rates. The court addressed whether the FCC had authority to preempt state ratemaking on depreciation and whether the commission complied with federal separations procedures. It held that the FCC lacked jurisdiction under the Communications Act of 1934 to dictate intrastate depreciation methods, rendering the preemption order unenforceable, and dismissed the remaining claims based on doctrines of exhaustion of state remedies and abstention. The decision rested on statutory limits on FCC authority to interstate matters and procedural requirements for federal intervention in ongoing state regulatory proceedings.
This case involved a constitutional challenge by day care providers, parents, and related associations to Arkansas statutes (Acts 123 of 1973, 518 of 1981, and 245 of 1983) that created exemptions from state licensing and regulatory requirements for certain religious child care facilities. Plaintiffs argued the laws violated the Establishment Clause of the First Amendment, the Due Process Clause due to vagueness, and the Equal Protection Clause by discriminating against non-exempt facilities. The court applied strict scrutiny under precedents like Larson v. Valente, examined the legislative history and certification requirements for exemptions (including substantial compliance with health/safety standards and distinctions based on facility organization dates), and noted arbitrary classifications and undefined terms such as 'religious child care facility.' The court granted summary judgment, holding the exemption scheme unconstitutional.
This case involved a taxpayer's suit to recover amounts paid under 26 U.S.C. § 4941(a)(1) after the IRS determined that his purchase of stock from his father's estate (which funded a charitable trust) constituted indirect self-dealing by a disqualified person with a private foundation. The court addressed whether the statute and related regulation were constitutional, whether the plaintiff qualified as a disqualified person, and whether the § 4941 exaction was a penalty rather than a tax for interest purposes. It held that the plaintiff was a disqualified person because he was a lineal descendant of a substantial contributor (his deceased father, treated as such under § 507(d)(2) as incorporated by § 4946). The court further held that § 4941(a)(1) imposes a penalty, not a tax, so interest could not be assessed when payment was made within ten days of notice, consistent with its prior ruling in Farrell v. United States.
Carl Albert Collins filed a federal habeas petition challenging his 1974 Arkansas conviction for capital felony murder and death sentence, primarily alleging ineffective assistance of counsel during the penalty phase because his attorneys presented no mitigating evidence. The court first addressed exhaustion of state remedies under Rose v. Lundy, accepting the state's concession that all claims had been exhausted. After an evidentiary hearing, the court denied relief, finding that counsel had thoroughly investigated potential mitigation witnesses and evidence but reasonably decided not to present it as a matter of trial strategy due to the absence of helpful information and the risk of introducing damaging facts about Collins's background; other constitutional challenges to the sentencing statute and procedures were either meritless, procedurally defaulted, or already resolved by state courts. The petition was therefore denied in full.
