Jennifer Jones, in Her Official Capacity as Clerk of the District Court of Benton County, Arkansas, Bentonville Division v. Professional Background Screening Association, Inc.

2020 Ark. 362, 610 S.W.3d 640
CourtSupreme Court of Arkansas
DecidedNovember 5, 2020
StatusPublished
Cited by5 cases

This text of 2020 Ark. 362 (Jennifer Jones, in Her Official Capacity as Clerk of the District Court of Benton County, Arkansas, Bentonville Division v. Professional Background Screening Association, Inc.) is published on Counsel Stack Legal Research, covering Supreme Court of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jennifer Jones, in Her Official Capacity as Clerk of the District Court of Benton County, Arkansas, Bentonville Division v. Professional Background Screening Association, Inc., 2020 Ark. 362, 610 S.W.3d 640 (Ark. 2020).

Opinion

Cite as 2020 Ark. 362 SUPREME COURT OF ARKANSAS No. CV-19-929

Opinion Delivered: November 5, 2020

JENNIFER JONES, IN HER OFFICIAL CAPACITY AS CLERK OF THE DISTRICT COURT OF BENTON APPEAL FROM THE PULASKI COUNTY, ARKANSAS, BENTONVILLE COUNTY CIRCUIT COURT, SECOND DIVISION DIVISION APPELLANT [NO. 60CV-18-5146]

V. HONORABLE CHRISTOPHER CHARLES PIAZZA, JUDGE PROFESSIONAL BACKGROUND SCREENING ASSOCIATION, INC. APPELLEE AFFIRMED ON DIRECT APPEAL; AFFIRMED ON CROSS-APPEAL.

COURTNEY RAE HUDSON, Associate Justice

Appellant Jennifer Jones, in her official capacity as Clerk of the District Court of

Benton County, Arkansas, Bentonville Division (“Jones”), appeals from the Pulaski County

Circuit Court’s order granting summary judgment to appellee Professional Background

Screening Association, Inc. (“PBSA”), on PBSA’s claim pursuant to the Arkansas Freedom

of Information Act (“FOIA”). For reversal, Jones argues that the circuit court erred in

granting partial summary judgment in favor of PBSA on its FOIA claim based upon its

erroneous interpretation of Arkansas Supreme Court Administrative Order Number 19

(“Order 19”). PBSA also filed a cross-appeal from the circuit court’s partial grant of summary judgment to Jones on PBSA’s claim for relief under 42 U.S.C. § 1983. We affirm on both

direct appeal and cross-appeal.

PBSA, f/k/a National Association of Professional Background Screeners, is a

nonprofit trade association that represents the interests of companies offering employment,

tenant, and volunteer background screening services. On July 23, 2018, PBSA filed a

complaint against Jones alleging (1) that Jones had interpreted and applied Order 19 to

PBSA members who request court records to perform background checks in a manner that

violated their right to access court records under the First Amendment to the United States

Constitution, as applied to the states through the Fourteenth Amendment, and other federal

law and (2) that its members’ requests for court records are instead governed by the Arkansas

Freedom of Information Act, Arkansas Code Annotated sections 25-19-101 et seq. PBSA

requested declaratory and injunctive relief, as well as costs and attorney’s fees.

According to the facts alleged in the complaint, an Arkansas PBSA member was

informed beginning in February 2018 that Order 19, not FOIA, governed its requests for

court records to be used for criminal-background checks. PBSA stated that Jones had

reiterated this position as recently as July 10, 2018, and it attached as an exhibit an FOIA

request by Courthouse Concepts for “any and all court records which relate to” a certain

individual. A response letter from Jones was also attached wherein she indicated that Order

19 applied to the request and attached a “Compiled Records License Agreement, Request

for Compiled Information Affidavit, and a Request for Compilation of Court Information.”

2 PBSA claimed that its requests for court records, such as docket sheets, do not fall

within Order 19’s definition of “compiled information,” which is “information that is

derived from the selection, aggregation or reformulation of information from more than one

court record.” Further, PBSA alleged that its members are unable to meet the certification

required by Order 19’s provisions on compiled information that they “must declare under

penalty of perjury that the request is made for a scholarly, journalistic, political,

governmental, research, evaluation, or statistical purpose, and that the identification of

specific individuals is essential to the purpose of the inquiry.” In addition, PBSA asserted

that the license agreement would preclude them from providing personal identifying

information to customers, subscribers, or other persons without express permission. PBSA

stated that, out of the dozens of Arkansas district courts, the Bentonville Division is one of

only three that continue to deny its members access to court records to perform criminal-

background checks “based on a misinterpretation of Order 19.”

Jones filed a motion to dismiss the complaint pursuant to Arkansas Rule of Civil

Procedure 12(b)(1) and 12(b)(6), claiming that PBSA had failed to state any facts upon which

relief could be granted and that its federal § 1983 claim was barred by sovereign immunity.

Jones further argued that PBSA lacked standing to bring the action and that its claims were

not ripe. In its response, PBSA asserted that Jones was not entitled to sovereign immunity

because it sought only prospective relief from her unconstitutional and ultra vires actions.

Furthermore, PBSA contended that it had standing to bring its action on behalf of its

members based on the doctrine of associational standing.

3 The circuit court held a hearing on Jones’s motion to dismiss on January 8, 2019.

Jones reiterated her sovereign-immunity argument with respect to the § 1983 claims and

conceded that she was objecting to the FOIA claim only on the basis of standing, not

immunity. The circuit court entered an order that same day denying the motion to dismiss.

Jones filed an answer to PBSA’s complaint on January 22, 2019. She denied the

allegations in the complaint and affirmatively asserted that the complaint was barred by

sovereign, statutory, and/or qualified immunity; that in her official capacity, she was not a

“person” amenable to suit under 42 U.S.C. § 1983; that she acted in good faith at all times

relevant to the material facts in the case; that her interpretation of Order 19 was reasonable

and consistent with Arkansas law, including the FOIA; and that even if she misinterpreted

Order 19, her position was substantially justified.

On May 3, 2019, PBSA filed a motion for summary judgment, arguing that there

were no genuine issues of material fact and that it was entitled to judgment as a matter of

law. It contended that the requests for court records made by its members such as

Courthouse Concepts were not requests for compiled information as defined in Order 19;

that Jones’s refusal to provide these records violated the FOIA, the First Amendment to the

United States Constitution, and federal common law; that Jones’s refusals were resulting in

significant injury to its members for which there was no adequate remedy at law; and that it

was entitled to declaratory and injunctive relief. PBSA attached as exhibits this court’s per

curiam opinion adopting Order 19; Jones’s deposition; and the affidavits of Melissa

4 Sorenson, who is the executive director of PBSA, and Paul Hickman, the president of

Courthouse Concepts, Inc.

In support of its motion, PBSA cited the following testimony from Jones’s deposition.

The Bentonville Division of the Benton County District Court retains records on two

separate computer systems: JustWare and PTS. The JustWare system contains records on all

new charges from May 2013 onward and is available to the public through a website called

JusticeWeb. The PTS system, which includes all records on cases opened prior to May 2013,

is not publicly accessible. PBSA indicated that only the PTS records are at issue in this suit.

When Courthouse Concepts requests records on a particular person, the court clerk first

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