City of Fort Smith, Arkansas v. Jennifer Merriott

Summary

The court reversed and dismissed both the illegal-exaction and unjust-enrichment claims arising from Fort Smith’s practice of landfilling most collected recyclables. It held that the unified sanitation fee remained reasonably related to the sanitation services identified in the ordinance and that the class failed to prove any wrongful financial benefit retained by the City. The court therefore vacated the class’s restitution award.