The Arkansas Supreme Court affirmed a Pulaski County Circuit Court decision that denied a Republican candidate's attempt to disqualify his primary opponent from the March 3, 2026 election for Arkansas House District 94.
John Kyle Day of Drew County filed a petition seeking to remove Laura "Missy" Michelle Wardlaw from the Republican primary ballot, arguing she was ineligible to run for public office due to a conviction under the Arkansas Hot Check Law, Arkansas Code Annotated section 5-37-302. The case was decided Feb. 11, 2026, by Associate Justice Courtney Rae Hudson.
Day, who is both a candidate and voter in the Republican Preferential Primary Election for House District 94, petitioned the circuit court for a writ of mandamus and declaratory judgment. House District 94 encompasses parts of Bradley, Desha, and Drew Counties, making it a multi-county race with significant regional implications.
The appellant's challenge centered on Wardlaw's criminal case disposition, which he characterized as "Guilty – Bond Forfeiture" in relation to the hot check violation. Day argued this conviction rendered Wardlaw constitutionally ineligible to seek public office under Arkansas law.
Day presented two primary arguments for reversal before the Arkansas Supreme Court. First, he contended the circuit court erred when it denied his petition and failed to declare Wardlaw ineligible based on her criminal case disposition. Second, he argued the circuit court improperly allowed Wardlaw to maintain "wholly inconsistent positions" and contradict concessions made by both herself and her counsel regarding the hot-check case.
The original petition was filed Dec. 23, 2025, as a verified petition for issuance of a writ of mandamus and declaratory judgment in Pulaski County Circuit Court, Third Division. The Honorable Cathleen V. Compton presided over the lower court proceedings before the case was appealed to the state's highest court.
The case involved multiple defendants beyond Wardlaw, including the Bradley County Board of Election Commissioners, Desha County Board of Election Commissioners, and Drew County Board of Election Commissioners. State officials named as defendants included Cole Jester in his official capacity as Arkansas Secretary of State, reflecting the statewide implications of candidate eligibility determinations.
Additionally, the Republican Party of Arkansas and Sharon Stuthard, in her official capacity as Secretary of the State Committee of the Republican Party of Arkansas, were named as parties to the proceedings. This broad defendant list underscores the systemic nature of election administration and candidate qualification processes.
The Supreme Court's affirmation of the circuit court's denial means Wardlaw remains eligible to appear on the March 3, 2026 Republican primary ballot for House District 94. The ruling preserves the status quo and allows the primary election to proceed with both candidates on the ballot.
Day's challenge appears to have been part of broader pre-election litigation aimed at determining candidate eligibility before voters cast their ballots. Such challenges are not uncommon in competitive primary races where candidates seek to remove opponents through legal means rather than electoral competition.
The Arkansas Hot Check Law, codified in Arkansas Code Annotated section 5-37-302, criminalizes writing checks with insufficient funds or when the account has been closed. The law is designed to protect merchants and individuals from fraudulent payment practices.
Candidate eligibility challenges often turn on interpretations of constitutional and statutory requirements for holding public office. These may include residency requirements, age limitations, criminal conviction restrictions, and other qualifications deemed necessary for public service.
The timing of Day's petition, filed in late December 2025 for a March 2026 primary, reflects the compressed timeline typical of pre-election legal challenges. Courts must balance thorough legal review with the practical need to resolve candidate eligibility questions before ballots are finalized and voting begins.
With the Supreme Court's affirmation, the Republican primary for House District 94 will proceed as scheduled with both Day and Wardlaw on the ballot. Voters in Bradley, Desha, and Drew Counties will ultimately decide between the candidates through the electoral process rather than through judicial intervention.
The case demonstrates the intersection of criminal law and election law, where past legal violations may impact future political aspirations. However, the specific legal standards for when criminal convictions disqualify candidates from public office remain subject to judicial interpretation and statutory construction.
The decision also highlights the role of Arkansas's election infrastructure, involving county election boards, the Secretary of State's office, and political party organizations in maintaining election integrity while ensuring qualified candidates can seek office. The multi-county nature of House District 94 required coordination among several election commissioners in the candidate qualification process.