Peterson v. Jefferson Cnty. Cir. Ct., 2014 Ark. 228

Peterson, pro se, appeals a May 30, 2013 Jefferson County Circuit Court dismissal of his petition for declaratory judgment.
Peterson has a lengthy criminal history culminating in an aggregate life sentence from 1992 convictions in Crawford and Sebastian Counties.
Earlier petitions for postconviction relief and habeas corpus were filed between 1998 and 2009, with several denials and unpublished per curiam dispositions.
In 2013 Peterson filed a declaratory-judgment petition containing interrogatories and affidavits from about ninety inmates asserting denial of justice and liberty, seeking to collaterally attack prior rulings.
The circuit court denied the petition as lacking merit and barred as a matter of law, a ruling the Arkansas Supreme Court affirms on appeal.
The court emphasizes judicial immunity, improper use of declaratory relief to challenge prior rulings, and the lack of a justiciable, ripe controversy for declaratory relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the declaratory-judgment petition was properly dismissed	Peterson alleging collateral attack on prior rulings and denial of relief	Judicial immunity and lack of justiciable controversy	Yes; the petition was properly dismissed
Whether the judges had jurisdiction and immunity to be sued	Judges exceeded authority and acted unlawfully	Judges had subject-matter jurisdiction and acted in their judicial capacities	Yes; judges had judicial immunity
Whether declaratory relief was an appropriate vehicle for Peterson's claims	Declaratory judgment should resolve due-process and equal-protection concerns	Declaratory relief cannot retry past rulings or substitute for habeas relief	Yes; declaratory relief not appropriate to challenge prior rulings
Whether Peterson's due-process claim has merit	He was denied hearings on pleadings	He had opportunities to be heard and to appeal	No; due-process rights were not violated as claimed
Whether Peterson's equal-protection claim has merit	Citizens are treated differently in habeas procedures	No factual showing of selective denial; classifications were rational	No; no demonstrated equal-protection violation

Pierson v. Ray, 386 U.S. 547 (1967) (absolute judicial immunity for acts within judicial capacity)
Mitchell v. Forsythe, 472 U.S. 511 (1985) (expands judicial-immunity doctrine in absolute terms)
Stump v. Sparkman, 435 U.S. 349 (1978) (scope of jurisdiction supports immunity when acting judicially)
Hutson v. State, 171 Ark. 1132, 287 S.W. 398 (1926) (Arkansas authority on judicial immunity)
Wise v. Norris, 2011 Ark. 362 (Ark. 2011) (declaratory-judgment limits and procedural posture in Arkansas)
Ark. Dep’t of Hum. Servs. v. Ross-Lawhon, 290 Ark. 578, 721 S.W.2d 658 (1986) (requirements for a valid declaratory judgment action)
Biedenharn v. Thicksten, 361 Ark. 438, 206 S.W.3d 837 (2005) (pleading standards and liberal construction for fact-pleading; abuse of discretion standard)
McCutchen v. City of Ft. Smith, 2012 Ark. 452 (Ark. 2012) (four requirements for declaratory relief; justiciable controversy)
Doe v. Weiss, 2010 Ark. 150 (Ark. 2010) (standard for reviewing dismissal under abuse-of-discretion; fact-pleading rule)