Case: Do No Harm v. Sanders

4:25-cv-00282 | U.S. District Court for the Eastern District of Arkansas

Filed Date: March 25, 2025

Closed Date: May 1, 2025

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Case Summary

In this case, two non-profits challenged state statutes requiring racial diversity on certain state licensing boards. On March 25, 2025, two advocacy organizations—Do No Harm (DNH) and the Foundation Against Intolerance and Racism (FAIR)—filed suit against the Arkansas Governor in the U.S. District Court for the Eastern District of Arkansas, represented by the Pacific Legal Foundation and private counsel. The case was assigned to District Judge Lee P. Rudofsky. The case arose from two Arkansas …

In this case, two non-profits challenged state statutes requiring racial diversity on certain state licensing boards.

On March 25, 2025, two advocacy organizations—Do No Harm (DNH) and the Foundation Against Intolerance and Racism (FAIR)—filed suit against the Arkansas Governor in the U.S. District Court for the Eastern District of Arkansas, represented by the Pacific Legal Foundation and private counsel. The case was assigned to District Judge Lee P. Rudofsky.

The case arose from two Arkansas statutes that required the Governor to consider race or ethnicity when making appointments to two state licensing boards. The plaintiffs alleged that these statutes violated the Equal Protection Clause and the Citizenship Clause of the Fourteenth Amendment.

The complaint targeted two Arkansas state boards: the Occupational Therapy Examining Committee and the Board of Examiners in Counseling. For both boards, Arkansas law mandated that at least one board member be a racial or ethnic minority. DNH and FAIR contended that these requirements prevented some of their members—who are white—from receiving equal consideration for appointment. 

The complaint asserted four causes of action through 42 U.S.C. § 1983: that the statutory racial and ethnic mandates violate the US. Constitution’s Fourteenth Amendment’s Equal Protection Clause (Counts I and III) and the Citizenship Clause (Counts II and IV). DNH and FAIR sought a declaratory judgment that the statutes violate the U.S. Constitution, a permanent injunction forbidding Arkansas from enforcing the statutes, and attorneys’ fees.

On April 21, 2025, Arkansas enacted a law removing racial diversity mandates on state boards. As a result, DNH and FAIR voluntarily dismissed their lawsuit on May 1, 2025. No decision on the merits was issued and the case is now closed.

Summary Authors

Gordon Pignato (5/9/2025)

People

For PACER's information on parties and their attorneys, see: https://www.courtlistener.com/docket/69789404/parties/do-no-harm-v-sanders/


Attorney for Plaintiff

Hyman, William Whitfield (Arkansas)

Jennings, Jeffrey Daniel (Arkansas)

Trotter, Caleb R. (Arkansas)

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Documents in the Clearinghouse

Document
1

4:25-cv-00282

Complaint

March 25, 2025

March 25, 2025

Complaint

Docket

See docket on RECAP: https://www.courtlistener.com/docket/69789404/do-no-harm-v-sanders/

Last updated Nov. 12, 2025, 3:50 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT filed by Foundation Against Intolerance and Racism Inc and Do No Harm against Sarah Sanders. (Fee $405, Receipt Number LIT9985.) No summons issued. (Attachments: # 1 Civil Cover Sheet) (ldb) (Entered: 03/25/2025)

1 Civil Cover Sheet

View on PACER

March 25, 2025

March 25, 2025

Clearinghouse
2

ORDER ON AMICUS BRIEFS. Signed by Judge Lee P. Rudofsky on 3/21/2023. (ldb) (Entered: 03/25/2025)

March 25, 2025

March 25, 2025

3

Deficiency Letter from Clerk of Court notifying party that Corporate Disclosure Statement not filed with first appearance, pleading, petition, motion, response, or other request (F.R.Cv.P. 7.1) re 1 Complaint. (ldb) (Entered: 03/25/2025)

March 25, 2025

March 25, 2025

4

Corporate Disclosure Statement (Rule 7.1) by Do No Harm, Foundation Against Intolerance and Racism Inc (Jennings, Jeffrey) (Entered: 03/27/2025)

March 27, 2025

March 27, 2025

Summons Issued as to Sarah Sanders and returned to counsel for plaintiff for service upon defendant. (jap)

March 31, 2025

March 31, 2025

5

NOTICE of Appearance by Caleb R. Trotter on behalf of Do No Harm, Foundation Against Intolerance and Racism Inc (Trotter, Caleb) (Entered: 04/08/2025)

April 8, 2025

April 8, 2025

6

WAIVER OF SERVICE Returned Executed as to Sarah Sanders by Foundation Against Intolerance and Racism Inc, Do No Harm. (Jennings, Jeffrey) (Entered: 04/08/2025)

April 8, 2025

April 8, 2025

7

NOTICE of Voluntary Dismissal by Do No Harm, Foundation Against Intolerance and Racism Inc (Jennings, Jeffrey) (Entered: 05/01/2025)

May 1, 2025

May 1, 2025

RECAP
8

(This is a TEXT ENTRY ONLY. There is no pdf document associated with this entry.) ORDER. The Court treats Plaintiffs' 7 Notice of Voluntary Dismissal as a self-executing notice of dismissal pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(i). The Clerk is directed to terminate this case. Signed by Judge Lee P. Rudofsky on 5/2/2025. (hml) (Entered: 05/02/2025)

May 2, 2025

May 2, 2025

Case Details

State / Territory:

Arkansas

Case Type(s):

Equal Employment

Public Accommodations/Contracting

Key Dates

Filing Date: March 25, 2025

Closing Date: May 1, 2025

Case Ongoing: No

Plaintiffs

Plaintiff Description:

(1) An "organization of over 16,000 medical professionals, students, and policymakers," and (2) an "organization that fights for equality for all individuals regardless of racial group membership."

Plaintiff Type(s):

Non-profit NON-religious organization

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

State of Arkansas, State

Defendant Type(s):

Jurisdiction-wide

Case Details

Causes of Action:

42 U.S.C. § 1983

Ex parte Young (federal or state officials)

Constitutional Clause(s):

Birthright Citizenship

Equal Protection

Other Dockets:

Eastern District of Arkansas 4:25-cv-00282

Available Documents:

Complaint (any)

Trial Court Docket

Outcome

Prevailing Party: None Yet / None

Relief Granted:

None

Source of Relief:

None

Issues

General/Misc.:

Pattern or Practice

Discrimination Area:

Hiring

Discrimination Basis:

National origin discrimination

Race discrimination

Affected National Origin/Ethnicity(s):

Other

Affected Race(s):

White

Presidential/Gubernatorial Authority:

Civil Service