Aamodt v. City of Norfork

Jason and Marian Aamodt sued the City of Norfolk, Arkansas, to enjoin the application of a 2008 zoning ordinance prohibiting the short-term rental of their property. The Aamodts also requested records under the Arkansas Freedom of Information Act (AFOIA). The district court granted summary judgment to the City. The Aamodts appealed, contending (1) the 2008 ordinance was invalid because it did not contain a map, and (2) the district court interpreted the AFOIA in violation of the Privileges and Immunities Clause. The Eighth Circuit Court of Appeals affirmed, holding (1) the Aamodts' first claim failed because their complaint made no such claim and the district court did not rule on it; and (2) the Aamodts' second claim failed because they did not assert this constitutional claim in the district court.