City of North Little Rock; Mayor Joe Smith; Alderman Debi Ross; Alderman Beth White; Alderman Linda Robinson…

Summary

The court held that the circuit court had subject-matter jurisdiction to entertain Pfeifer’s mandamus petition because the governing improvement-district statute expressly authorizes mandamus to enforce statutory duties. It further held that the City’s failure to make the required statutory finding in an ordinance justified mandamus, but that the circuit court exceeded its authority by directing the City to make particular findings and perform additional specified tasks. The judgment was affirmed as modified. Justice Hart, concurring in part and dissenting in part, agreed that jurisdiction existed but would have denied mandamus because Pfeifer had an adequate appeal remedy and the City’s decision involved legislative discretion.