Question 1: Is there any authority in Arkansas law for a county assessor to reappraise property that was assessed as of January 1, 2026 after July 1, 2026 to change the school district on applicable property to a newly isolated school district under Act 919 of 2025? The newly isolated school district was approved by voters at the March 2026 election and became a functioning school district as of July 1, 2026.
Question 2: Is there any authority in Arkansas law for a quorum court to levy a millage in its November or December 2026 levy ordinance for a newly isolated school district that became a functioning school district on July 1, 2026 but has not passed a millage approved by voters?
Question 3: Is there any authority in Arkansas law for a county treasurer to distribute property tax funds to a school district that has not had a millage levied by quorum court ordinance?
Question 4: Under existing Arkansas law, where the subject property was assessed as of January 1, 2026 in the previously consolidated school district, and if the answer to Question 1 is no, is there any way to get the newly isolated school district on the tax statements that go out beginning in February 2027?
Question 5: If the county treasurer distributes all of the property tax funds that were assessed and collected for the previously consolidated school district to the previously consolidated school district, should the previously consolidated school district send the appropriate amount of funds to the newly isolated school district?
Brief Response: I must respectfully decline to opine on your questions because they are the subject of pending litigation. It is the long-standing policy of the Office of the Attorney General, as a member of the executive branch, to decline to opine on matters that are pending before the courts for resolution.
Question 1: Under the applicable state and federal law, what authority does a county with no zoning ordinances in place have to regulate a proposed data center before a county construction permit is issued?
Brief Response: Under Arkansas law, a county that has not adopted zoning ordinances has limited authority to regulate a proposed data center before issuing a construction permit. It may not deny the permit on zoning or land-use compatibility grounds because no zoning scheme exists under which the proposed use can be prohibited or conditioned. But the county may enforce otherwise valid ordinances and statutory requirements concerning matters such as health and safety, flood-prone areas, subdivision development, road access, setbacks, and applicable building requirements.
Question 2: Under the applicable state and federal law, what authority does a county with no zoning ordinances in place have to regulate a data center after a county permit is issued and construction has begun?
Question 3: After a county with no zoning ordinances in place has issued a construction permit and construction has begun, does said county have the authority to enact an ordinance changing the requirements for the permit by imposing additional requirements for the permit, increasing the standards to be met or fees to be paid, delaying construction, changing the methods of construction, requiring reports, or increasing compliance expenses?
Brief Response: In response to Questions 2 and 3, a county retains regulatory authority after issuing a construction permit; however, in one case the Arkansas Supreme Court held substantial reliance on a building permit equitably estopped the county from revoking the building permit. A permit, standing alone, does not create a contract or a vested right to remain governed by the laws in effect when the permit issued. Thus, the permit holder generally remains subject to later regulations lawfully enacted under the governmentโs police power.
Question 4: Under the applicable state and federal law, does a county with no zoning ordinances in place have the authority to enact an ordinance to regulate a data center based upon the amount of electricity or the amount of water it is expected to use, after the data center has secured contracts for such services and the Public Service Commission and the particular utility entities have approved such contracts?
Brief Response: Public Service Commission (โPSCโ) approval of utility-service contracts does not foreclose otherwise lawful county regulation, but the county may not override matters committed to the PSC by the General Assembly.
Question 5: If a county with no zoning ordinances in place causes foreseeable damage to a data center through an action that is later determined to be ultra vires on the part of the county, may the county be held liable for such damages in state or federal court?
Brief Response: Arkansasย Codeย ยงย 21-9-301 generally immunizes counties from tort liability, including negligence claims, except to the extent the county has applicable liability-insurance coverage. A finding that county action was ultra vires does not itself create a damages remedy or overcome statutory immunity. Rather, ultra vires claims are limited to prospective injunctive relief, and monetary damages may be recovered only if immunity has been waived through applicable insurance coverage.
Question 6: After a county issues a construction permit upon the applicantโs satisfaction of all conditions, and the applicant enters into contracts on the strength of that permit and begins construction, does said county have the authority to enact an ordinance that retroactively adds conditions to the permit and causes work to cease until new conditions are met?
Brief Response: When a permit has been lawfully issued, the permit holder has entered contracts and incurred liabilities in reliance on it, and construction has begun, the Arkansas Supreme Court has held that the permit holder may acquire โa kind of property rightโ entitled to protection in some circumstances. In Tankersley Bros. Industries, Inc. v. City of Fayetteville, the Arkansas Supreme Court explained that, after such reliance, a permit generally may not be revoked without cause or in the absence of public necessity. An ordinance that retroactively adds new permit conditions and stops construction until those conditions are satisfied could therefore operate as a material alteration or effective revocation of the permit and might be subject to challenge under Tankersley.
Question: Does a county possess the legal authority to have and place a county-wide sales tax on the ballot that is solely and entirely dedicated and designated for fire departments within the county?
Brief Response: A countyโs authority to place a county-wide sales tax on the ballot that is solely and entirely dedicated to fire departments within the county depends on the statutory authority under which the tax is levied. Under A.C.A. ยงย 26-73-113, a county may place such a tax on the ballot if the proposed taxโs use falls within the permissible uses listed in A.C.A. ยงย 26-73-113(a)(2). Alternatively, under A.C.A. ยงยงย 26-74-201 through -223 or A.C.A. ยงยง 26-74-301 through -321, a county may place such a tax on the ballot if the ballot title and levying ordinance specify the desired distribution and the affected local governments execute an interlocal agreement concerning that distribution.