Carlock v. City of Blytheville (Majority)Annotate this Case
The Supreme Court affirmed the order of the circuit court dismissing Appellant's illegal-exaction complaint against the City of Blytheville, Arkansas, holding that the circuit court did not abuse its discretion in dismissing the complaint.
The City passed an ordinance calling for a special election to be held on a one-cent sales and use tax to be collected for fifteen months. The proposed tax was approved at the special election. Appellant later filed a class action complaint alleging that the excess revenue was an illegal exaction because the tax was approved in order to pay the City's debt to the federal government. The trial court dismissed the complaint, finding that, based on the wording of the ballot title, the City's use of the excess funds to pay payroll taxes was authorized and there was no illegal exaction. The Supreme Court affirmed, holding that the trial court properly utilized the enabling ordinance and ballot title in determining the approved uses for the excess funds.