Drew Robinson v. John Felts, Chairman of the Arkansas Parole Board
2025 Ark. 67
Ark.2025Background
- Drew Robinson, an inmate serving sentences for robbery and firearm possession, was denied parole multiple times by the Arkansas Post-Prison Transfer Board, most recently due to the seriousness of his crimes and his prior history.
- Robinson challenged the parole denial by seeking declaratory and mandamus relief against John Felts, the Parole Board chairman, in circuit court.
- Felts moved to dismiss, arguing sovereign immunity, lack of justiciable controversy, and quasi-judicial immunity.
- The circuit court dismissed Robinson’s petition without prejudice for failure to state a claim and to join necessary parties.
- Robinson appealed the dismissal instead of amending his complaint, converting the dismissal to one with prejudice upon affirmance by the Supreme Court of Arkansas.
- A dissenting justice argued that the case should be dismissed for lack of jurisdiction because the State was improperly made a defendant in a civil action instead of in Robinson’s underlying criminal cases.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Declaratory relief against Board Chairman | Felts should grant new hearing and relief | Felts lacks unilateral authority; other members unnamed | Dismissal proper; relief not available |
| Sufficient parties joined | Not addressed substantively by Robinson | Necessary Board members omitted | Dismissal for failure to join parties |
| Stating a claim for relief | Alleges wrongful denial of parole | Fails to plead facts supporting relief sought | Dismissal for failure to state claim |
| Appropriateness of mandamus | Entitled to writ compelling Board action | Absent right to declaratory relief, mandamus unavailable | No basis for mandamus relief |
Key Cases Cited
- Hollingsworth v. First Nat’l Bank & Tr. Co. of Rogers, 311 Ark. 637 (discussing appealability of dismissal orders)
- Orr v. Hudson, 2010 Ark. 484 (clarifying when dismissal without prejudice becomes appealable)
- Servewell Plumbing, LLC v. Summit Contractors, Inc., 362 Ark. 598 (addressing effect of appellate affirmance on dismissal without prejudice)
- Trammel v. Payne, 2023 Ark. 177 (explaining authority to effectuate declaratory relief)
- Carroll v. Hobbs, 2014 Ark. 395 (mandamus unavailable absent entitlement to declaratory relief)