The Court Spoke, the Ballot Remains, and a District 94 Race Moves Forward

Political succession by spouses is a familiar pattern in democracies, and Arkansas is no exception. In House District 94, Laura Wardlaw is running in the Republican primary in a safely Republican district, seeking to succeed her husband, Jeff Wardlaw, who is barred by term limits. Such transitions are common in state politics and often pass with little public attention.

This race, however, unfolded differently. What might have been a routine primary escalated into a legal battle that reached the Arkansas Supreme Court. A disqualification challenge against Wardlaw, tied to a disputed misdemeanor case, pushed the contest into the headlines. A ruling issued on Feb. 11 in her favor cleared the way for the race to proceed to the March 3 ballot, elevating the profile of the primary and turning it into a serious competitive contest within the Republican field.

Constitutional Questions and a Misdemeanor Conviction

Many wondered how Laura Wardlaw was able to enter the House race despite a past misdemeanor conviction that raised constitutional questions about her eligibility. The Arkansas Constitution prohibits anyone convicted of embezzlement of public money, bribery, forgery, or other infamous crimes from serving in the state legislature or holding other state office.

Wardlaw was found guilty in 2018 of passing a hot check. Her decision to remain in the race led to a lawsuit involving House District 94 candidate Laura “Missy” Wardlaw, filed on Monday, Dec. 22, 2025.

Legal precedent appeared to weigh against her eligibility. UA Little Rock Bowen School of Law Professor Robert Steinbuch said that precedent includes hot check convictions.

“A hot check conviction means you gave someone a check, you knew there were insufficient funds, and yet you did it in a dishonest fashion,” Steinbuch said. “She’s simply not entitled to hold office in the state of Arkansas.”

In 2020, the Pulaski County Circuit Court ruled that Democratic nominee Jimmie Wilson was ineligible to serve in the state legislature because of decades-old financial misdemeanor convictions, a ruling that the Arkansas Supreme Court later affirmed.

The Legal Challenge Raised by Opponent

Wardlaw’s opponent, John Kyle Day, moved the dispute from public debate to the courtroom by filing a lawsuit seeking her disqualification.

“I hope to do this as a public service. In the event that my opponent would by chance win the election, she would not be eligible to serve. And then we would have to have the taxpayers pay for a special election. Our constituents in these three counties would have no representation,” Day said.

In December, Day asked the Pulaski County Circuit Court to disqualify his opponent, Laura “Missy” Wardlaw, from running to represent House District 94 in the Legislature.

After a trial, on Jan. 13, Circuit Judge Cathleen Compton ruled that Wardlaw may remain on the March 3 ballot. Compton sided with Wardlaw’s attorney, who argued that the candidate was eligible because she forfeited bond and did not plead guilty or face trial over the misdemeanor charge.

Appeal to the Arkansas Supreme Court

Day’s attorney appealed the circuit court ruling, pushing the dispute to the Arkansas Supreme Court.

The Supreme court upheld the lower court’s decision, clearing the way for Wardlaw to remain on the ballot in the March Republican primary, despite her opponent’s effort to have her disqualified.

In a 6-1 decision, the justices determined that John Kyle Day “failed to prove” that Laura “Missy” Wardlaw had been convicted of an “infamous crime.” The two candidates are now facing off in the March 3 Republican primary for a House seat in southeast Arkansas.

Under the Arkansas Constitution, convictions for “infamous crimes,” including embezzlement and forgery, bar individuals from holding elected office. Wardlaw was charged in 2018 with writing a hot check and later forfeited bond, which typically occurs when a defendant fails to appear in court. Day argued in Pulaski County Circuit Court that the bond forfeiture should be treated as a conviction, a claim the courts ultimately rejected.

Supreme Court Opinions

In an opinion written by Justice Courtney Hudson, the court sided with Wardlaw’s attorney’s argument that bond forfeiture does not constitute a conviction or a guilty plea. Bond forfeiture typically happens when a defendant fails to appear in court.

“It is undisputed that there was no criminal trial, as Wardlaw never even appeared to be arraigned, so there was no guilty verdict,” Special Justice Tiffany Milligan Brown wrote in her concurring opinion.

Milligan Brown was one of three special justices appointed by Republican Gov. Sarah Huckabee Sanders for the case after Justices Cody Hiland, Nicholas Bronni, and Barbara Webb recused themselves. 

Justice Rhonda Wood dissented, arguing that Wardlaw should not have been considered eligible.

“Because a preponderance of the evidence showed that Wardlaw was guilty of a hot-check violation, Day had a clear and certain right to a writ of mandamus ordering votes for Wardlaw not to be counted,” Wood wrote in her dissenting opinion.

A Heated Primary Is the Result

Now cleared to run, Wardlaw remains on the ballot, though the legal controversy continues to shape the race. Her opponent, John Kyle Day, has made the dispute a central part of his campaign, framing it around questions of trust, eligibility, and accountability.

Wardlaw and Day are competing for a reliably Republican House seat in conservative south Arkansas, covering Monticello, Warren, and McGehee. The seat is currently held by Wardlaw’s husband, giving Laura Wardlaw a structural and political advantage. As March 3 approaches, the legal battle has intensified the contest and drawn broader attention to the Republican primary.

In the 2024 election, Democrat Curley Jackson ran for the seat and received 34.5 percent of the vote. This year, however, Democrats are not contesting the race, and no independent candidates have filed. As a result, the March 3 Republican primary will effectively decide who represents House District 94 in the Arkansas Legislature.