Charity Tarr, Aprn-Cnp, Dnp v. Arkansas State Board of Nursing

2025 Ark. App. 195, 711 S.W.3d 799
CourtCourt of Appeals of Arkansas
DecidedApril 2, 2025
StatusPublished

This text of 2025 Ark. App. 195 (Charity Tarr, Aprn-Cnp, Dnp v. Arkansas State Board of Nursing) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Charity Tarr, Aprn-Cnp, Dnp v. Arkansas State Board of Nursing, 2025 Ark. App. 195, 711 S.W.3d 799 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 195 ARKANSAS COURT OF APPEALS DIVISION II No. CV-23-832

CHARITY TARR, APRN-CNP, DNP Opinion Delivered April 2, 2025

APPELLANT APPEAL FROM THE PULASKI COUNTY CIRCUIT COURT, V. SEVENTEENTH DIVISION [NO. 60CV-23-1971] ARKANSAS STATE BOARD OF NURSING HONORABLE MACKIE M. PIERCE, APPELLEE JUDGE

AFFIRMED

CINDY GRACE THYER, Judge

Charity Tarr appeals the order of the Pulaski County Circuit Court denying her

petition for judicial review and affirming the decision of the Arkansas State Board of Nursing

(“the Board”) to suspend her nursing license. Tarr argues that the Board’s decision was

improper because she was not given proper notice of the Board’s initial letter of reprimand.

In addition, she argues that the Board’s sanction was too harsh. We find no error and affirm.

I. Factual and Procedural Background

Tarr has been a licensed registered nurse (RN) since 1999 and an advanced practice

registered nurse (APRN) since 2017, although both of her licenses expired in November

2020. On June 30, 2021, the Board sent Tarr a letter of reprimand (LOR) via certified mail

and through the Board’s online nurse portal. The LOR informed her that on January 9, 2020, the Board received a complaint reporting that Tarr was found to be involved in an

unprofessional relationship with a patient.1 Consequently, the LOR directed Tarr to provide

evidence that she had completed a “Nurse and Professional Behaviors” course within six

months.

Board staff reviewed the Nurse and Professional Behaviors course roster in January

2022 and determined that Tarr had not enrolled in the required course. On March 7, 2022,

the Board sent a notice to Tarr via both first-class mail and the nurse portal informing her

that she had until March 18, 2022, to submit a certificate showing she had completed the

course or she would be scheduled for a hearing before the Board regarding her

noncompliance. Tarr failed to contact the Board or provide a course-completion certificate.

As a result, on January 26, 2023, the Board mailed Tarr an “Order and Notice of Hearing”

informing her that a formal hearing would be held on February 15, 2023, at which she could

offer witnesses or evidence in defense of the charge that she had violated the terms of the

LOR.

At the February 15 hearing, Board Assistant Director Lisa Wooten testified that on

June 30, 2021, the LOR was sent to Tarr via the nurse portal and was mailed to her last-

known address via certified mail, and the “green card” was signed by Tarr on July 1,

2021.Tarr did not, however, view the letter in the portal. Likewise, the March 7 letter was

1 Tarr’s employer, Conway Behavioral Health Hospital, conducted an investigation and determined that Tarr was involved in an unprofessional relationship with a patient for whom she provided care.

2 sent by first-class mail to Tarr’s last-known address, the letter was not returned, and the letter

in the portal was not viewed.

Tarr appeared pro se at the hearing and asserted that she had received the hearing

notice only the day before and that the first time she had ever seen the LOR was the day of

the hearing. She said she was “agreeable to take the course” but “just did not know that was

something that I even had to do.” She testified that the mark on the green card was not her

signature and noted that the card did not specify whether the person signing “was the agent

or the addressee.” She also denied that the handwritten name “Charity Tarr” on the green

card was in her handwriting.

Tarr acknowledged that her licenses expired in 2020 and that she had not attempted

to renew them. She said that she no longer used the email on file with the Board where the

nurse-portal messages had been sent. She added that she updated her email address with the

Board the day of the hearing and agreed that the Board would have had no way of contacting

her if it did not have her correct email. She also admitted that she had not “been checking

the portal or anything” for the last two years. Tarr testified that although she knew there was

a complaint against her, she did not know the Board had sent her an LOR. She said she

thought she turned in all of her paperwork to her attorney and then never heard anything

else, so she “assumed that was done [and] the complaint was taken care of.”

Wooten was recalled to clarify that when the Board issues an LOR, the offending

party is given six months to complete the course. When the Board noticed that Tarr had not

turned her coursework in on time, she was sent another letter and given another six months

3 to complete the course. Wooten explained that if Tarr had communicated with the Board

and said she needed more time, she could have gotten an extension.

At the conclusion of the hearing, the Board found that Tarr was in violation of the

Board’s rules. Written findings of fact and conclusions of law were entered on February 24,

2023, formalizing the Board’s findings from the hearing and specifically finding that the

LOR was sent by certified mail to Tarr’s last-known mailing address on file with the Board

and that it was signed by Tarr on July 1, 2021. Tarr’s license was therefore suspended until

she satisfied the terms of the LOR.

Tarr subsequently petitioned for judicial review in the Pulaski County Circuit Court.

In her petition, she argued that the mark on the green card accompanying the LOR was not

her signature; therefore, because it was “never properly served on her, she was unaware that

the Board had issued [the LOR] to her or that she had to complete the course.” She asserted

that had she known about the LOR, she would have asked for a hearing and defended

herself. She also complained that she received the order and notice of hearing informing her

of the February 15, 2023 hearing on February 14, so she was unable to arrange for counsel

to represent her at the hearing. Tarr asserted that the Board’s hearing process violated her

due-process rights and that there was no evidence that she was properly served with the LOR

and its requirement that she take the necessary coursework. She further claimed that the

decision to suspend her license was unduly harsh and was therefore arbitrary, capricious, or

an abuse of discretion. She therefore sought an order from the circuit court reversing the

Board’s order suspending her nursing license.

4 The circuit court held a hearing on Tarr’s petition for judicial review at which it heard

arguments from counsel but did not hear additional testimony. Tarr’s counsel again argued

that Tarr never received the letter of reprimand, that the mark on the green card was not her

signature, and that she never got the March 2022 letter reminding her of the need to take

the requisite course.

Counsel for the Board argued that while Tarr may have claimed not to have gotten

the letter of reprimand, the Board “looked at the green card evidence, they looked at her

direct testimony that was contrary, [and] they put more weight on the green card evidence.”

He added that it was the Board’s position, as the trier of fact, to weigh the evidence, and it

was also the Board’s prerogative to believe or disbelieve any witness. Because the evidence

before the Board included the green card as well as Tarr’s testimony that she did not keep

her email address up to date, counsel argued that the Board’s decision was supported by

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Related

Emily Best v. Arkansas State Board of Nursing
2026 Ark. App. 9 (Court of Appeals of Arkansas, 2026)

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2025 Ark. App. 195, 711 S.W.3d 799, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charity-tarr-aprn-cnp-dnp-v-arkansas-state-board-of-nursing-arkctapp-2025.