Gerald Robinson, in His Official Capacity as County Judge of Jefferson County, Arkansas v. Lafayette Woods, Jr., in His Official Capacity as Sheriff of Jefferson County, Arkansas

── Gerald Robinson, in His Official Capacity as County Judge of Jefferson County, Arkansas v. Lafayette Woods, Jr., in His Official Capacity as Sheriff of Jefferson County, Arkansas ── Court: Court of Appeals of Arkansas Date: April 08, 2026 Category: General Cite as 2026 Ark. App. 225 ARKANSAS COURT OF APPEALS DIVISION I No. CV-24-685 GERALD ROBINSON, IN HIS Opinion Delivered April 8, 2026 OFFICIAL CAPACITY AS COUNTY APPEAL FROM THE JEFFERSON JUDGE OF JEFFERSON COUNTY, COUNTY CIRCUIT COURT ARKANSAS [NO. 35CV-22-199] APPELLANT HONORABLE GARY ARNOLD, V. JUDGE LAFAYETTE WOODS, JR., IN HIS OFFICIAL CAPACITY AS SHERIFF OF JEFFERSON COUNTY, ARKANSAS APPELLEE AFFIRMED WENDY SCHOLTENS WOOD, Judge Gerald Robinson, the county judge of Jefferson County (Judge Robinson), appeals from the Jefferson County Circuit Court’s order holding him in contempt for arbitrarily and capriciously denying claims for payment submitted to him by Jefferson County Sheriff Lafayette Woods, Jr. (Sheriff Woods). On appeal, Judge Robinson argues that the order he was found to have violated was not sufficiently clear to form the basis of a contempt finding, and even if it was sufficiently clear, his denials of Sheriff Woods’s claims were not arbitrary and capricious. We affirm.  I. Procedural History This case began in March 2022 when Sheriff Woods filed a petition against Judge Robinson and all the Jefferson County justices of the peace. Sheriff Woods sought a declaration that Ordinance 2022-136, which set the 2022 budget for Jefferson County, was invalid and asked the court for a writ of mandamus compelling the Jefferson County Quorum Court to appropriate additional funds to the Jefferson County Sheriff’s Department. Sheriff Woods filed a first amended petition in May seeking the same relief, and a second amended petition in August seeking the same relief plus a declaration that Ordinance 2021-27, which adopted a job requisition/pre-offer form for use by county officials, was invalid because the ordinance was not properly enacted and was unconstitutional because it required the county judge’s signature. On January 26, 2023, Sheriff Woods filed a third amended complaint to supplement his earlier petitions, adding the claims relevant to this appeal in which he alleged that Judge Robinson had arbitrarily and capriciously denied his requests for payment. On February 6, the circuit court granted a motion to dismiss filed by Judge Robinson and the justices of the peace as to all claims in the original petition and the first amended petition. On September 14, the court held a hearing on the remaining claims. At the outset of the hearing, the court granted Sheriff Woods’s motion for partial summary judgment as to Ordinance 2021-27, finding that it was not properly enacted and was, therefore, invalid for failure to comply with the requisite rules; the court entered an order on November 29 reflecting this decision. The only remaining issues were those regarding Judge Robinson’s 2 denial of Sheriff Woods’s payment requests, and the court heard testimony and received evidence on these issues. Also on November 29, the circuit court entered findings of fact and conclusions of law (the November order) recognizing that the county quorum court is required by law to prepare a yearly budget and that the county judge has the power to “authorize and approve disbursement of appropriated county funds.” Ark. Const. Amend. 55 § 3. By statute, the county judge must review all claims for payment to ensure that they comply with the purpose for which the funds were appropriated. Ark. Code Ann. § 14-14-1102 (Repl. 2013). The court then entered the following: FINDINGS OF FACT