Mississippi County v. City of Osceola, 2017 Ark. 63

Mississippi County is divided by Act 81 of 1901 into two judicial districts: the Osceola District (Osceola) and the Chickasawba District (Blytheville), with §20 directing that county revenues be used for the exclusive benefit of the district where they arise.
In 2014 voters approved a countywide sales-and-use tax to support the county hospital system.
On April 26, 2016 the Quorum Court sought to redirect and extend part of that tax and to authorize bonds to finance a new county courthouse to be located in Blytheville; it passed Ordinance O-2016-05 (changing tax use), a referral resolution for a special election, and Ordinance O-2016-06 (calling for bonds) for an August 9, 2016 special election.
The City of Osceola and two Osceola taxpayers sued to enjoin the special election, alleging the measures violated Act 81 §20 by imposing taxation that would not exclusively benefit the Osceola District and claiming statutory notice and ordinance amendment defects.
The Mississippi County Circuit Court granted a temporary injunction enjoining the August 9, 2016 special election; County appealed to the Arkansas Supreme Court.
The Supreme Court dismissed the appeal as moot because the election date had passed and because a companion Supreme Court decision resolved the substantive Act 81 issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Act 81 §20 prohibits a countywide sales-and-use tax or bond issuance to fund a new courthouse in Blytheville	City: Act 81 §20 prevents countywide taxing/benefit diversion; Osceola would bear tax burden without exclusive local benefit	County: Act 81 does not bar redirecting/using tax proceeds or issuing bonds for courthouse in Blytheville	Court: Appeal dismissed as moot; companion case upheld that Act 81 bars such measures (court rejected County's contention)
Whether the circuit court erred in granting a temporary injunction enjoining the Aug. 9, 2016 special election	City: Injunction proper to prevent unlawful taxation and procedural defects	County: Injunction improper; election should proceed	Court: Appeal moot (election passed); companion decision resolved substantive legality in favor of City’s position
Whether the County complied with statutory notice requirements for ordinance amendments and election referral	City: County failed to follow required notice/amendment procedures	County: County followed statutory requirements	Held: Moot; alleged defects were among claims supporting injunction but appeal dismissed as moot
Whether an expedited/accelerated appeal could affect the scheduled special election	County: Requested accelerated briefing to obtain relief before election	City: Mootness argument; election date would pass	Held: Moot — election date passed; appeal dismissed

Terry v. White, 374 Ark. 387 (recognizing mootness when judgment would have no practical legal effect)
Ark. Gas Consumers, Inc. v. Ark. Pub. Serv. Comm'n, 354 Ark. 37 (discussing exceptions to mootness doctrine such as issues capable of repetition yet evading review and public interest considerations)