Can the City of Little Rock ban all firearms at the Little Rock Zoo?
Subject
Whether the City of Little Rock's no-exceptions firearms-prohibition sign at the Little Rock Zoo, which sits inside War Memorial Park, violates A.C.A. § 14-54-1411 (Arkansas's local firearms preemption statute). AG Tim Griffin (Assistant AG Justin Hughes drafting) concluded the sign is unlawful as written.
Plain-English summary
Senator Mark Johnson sent the AG a photograph of a sign posted at the Little Rock Zoo. The sign, "by order of the City Manager," tells the public that carrying handguns and any other firearms or deadly weapons on "City property" is prohibited "at any time" with "no exceptions," authorizes searches, and exempts only active and retired Little Rock Police and other LE personnel required to carry as a job condition. Senator Johnson asked whether the sign violates Arkansas's firearms-preemption statute, A.C.A. § 14-54-1411.
The AG's answer is yes. Section 14-54-1411 broadly bars cities, towns, and counties from regulating firearms in any way unless state or federal law authorizes the regulation. The opinion walks through the framework:
The first question is whether the Zoo is a "municipal park" or a "publicly owned building or facility." That matters because under § 5-73-122 (the general state ban on loaded firearms in publicly owned buildings or facilities), municipal parks are excluded from the "facilities" definition by Act 693 of 2021. The opinion concludes the Zoo is a municipal park: it sits in War Memorial Park, the City's own ordinance (Little Rock Code § 22-211) lists "a zoological museum" among its parks-and-recreation system, and it operates under both the Parks and Recreation Department and the Zoo Department.
That conclusion drives two carry rights at the Zoo:
- Unlicensed open carry, in the open areas of the Zoo (not inside buildings). Act 638 of 2021 amended § 5-73-122(a)(3)(F), and Act 693 of 2021 amended § 5-73-122(a)(4) to remove municipal parks from the "facility" definition, opening up open carry in the open spaces of municipal parks.
- Enhanced concealed carry (E-CHCL), both inside buildings and in open areas of the Zoo. Section 5-73-122(a)(3)(D) lets E-CHCL holders carry concealed in publicly owned buildings or facilities, with four exceptions at (D)(i)–(iv) (courtrooms or state administrative hearings, K–12 schools and public daycares, prisons, and § 5-73-325 firearm-sensitive areas like the State Hospital, UAMS, or collegiate athletic events). None of those four exceptions applies to the Little Rock Zoo.
The City's signage authority is narrower than its sign claims. Under § 5-73-306(18)(A), a person or entity controlling a place can post signs (clearly readable from at least 10 feet at each entrance) that prohibit standard concealed-carry license (CHCL) holders from carrying concealed in that place. That authority applies only to standard CHCL holders, not to E-CHCL holders or unlicensed open carriers. And § 5-73-306(18)(B)(iv) confirms that subdivision (18)(A) does not reach E-CHCL holders carrying under § 5-73-322(g) and (h) on local-government property.
Putting it together: the City's sign overreaches in two specific ways. (1) It bars all firearms with "no exceptions," which violates the rights of E-CHCL holders to carry into Zoo buildings and open areas, and the rights of unlicensed open carriers to carry loaded handguns in the Zoo's open areas. (2) It does not even acknowledge the limited signage authority the City does have. The AG's bottom line: the sign violates § 14-54-1411 as currently worded, and the City must revise it to bring it into compliance with §§ 14-54-1411, 5-73-122, and 5-73-306.
What this means for you
If you are a Little Rock resident or visitor planning to go to the Zoo armed
The legal posture is in flux. The AG opinion says the sign is unlawful as written, but the opinion is persuasive authority, not a court ruling, and the City has not (as of this opinion) taken the sign down or revised it. If you carry, three things matter for your specific situation:
- Unlicensed open carry: If you are openly carrying a loaded handgun without a license, the AG opinion says state law lets you carry in the Zoo's open areas (not in buildings). You may still be confronted by Zoo staff or Little Rock Police following the City's posted policy. The opinion gives you a legal argument; it does not guarantee you avoid an encounter.
- Standard concealed-carry license (CHCL): The City may lawfully exclude you with a compliant § 5-73-306(18)(A) sign (clearly readable from 10 feet at each entrance, stating that "carrying a handgun is prohibited"). The current sign does not match that statutory format precisely, but the City has the authority to use a compliant sign to bar you. A safer practice is to leave the firearm secured.
- Enhanced concealed carry (E-CHCL): The AG opinion says the City cannot exclude you from Zoo buildings or open areas. Section 5-73-306(18)(B)(iv) takes you outside the City's signage authority on local-government property.
In all three lanes, expect that the on-the-ground experience may not match the legal text until the City revises the sign or a court rules. If your goal is avoiding a confrontation, treat this as a developing area.
If you are on the Little Rock City Council, City Attorney's office, or a parks administrator
The opinion is a roadmap for what compliance looks like. The current sign needs revision in three specific ways:
- Drop the "no exceptions" language. The City has no authority to bar E-CHCL holders or unlicensed open carriers in the Zoo's open areas. A sign that says it does is unlawful under § 14-54-1411.
- Match the § 5-73-306(18)(A)(i)–(ii) statutory text precisely. A valid CHCL-exclusion sign needs to say "carrying a handgun is prohibited," be at every entrance, and be readable from at least 10 feet. The current text reaches further than the statute.
- Distinguish open-area Zoo grounds from enclosed Zoo buildings. Unlicensed open carriers have rights in the open areas; they do not have rights in the enclosed buildings. A revised sign or signage scheme needs to account for that distinction.
Practically, the City has two compliant options. Option A: limit the sign to a CHCL-only exclusion (knowing that does not cover E-CHCL holders or unlicensed open carriers). Option B: petition the General Assembly for additional carve-outs, or seek § 5-73-325 firearm-sensitive-area approval through the Arkansas State Police if the Zoo qualifies (it likely does not, given the statutory list).
If you hold a CHCL or E-CHCL elsewhere in Arkansas
This opinion is the most explicit AG synthesis to date of how cities can and cannot use signs to limit carry on municipal park property. Three takeaways for any Arkansas city park, not just the Zoo:
- A blanket "no firearms" sign at a municipal park violates § 14-54-1411.
- Cities can validly use § 5-73-306(18)(A) signs to exclude standard CHCL holders, but only with statutorily compliant text and placement.
- Cities cannot use such signs to exclude E-CHCL holders carrying under § 5-73-322(g)–(h) on local-government property.
If you encounter a noncompliant sign at another Arkansas city park, this opinion (read together with Ops. 2025-031 and 2025-051) is your statutory authority for pushing back through the city attorney's office or by formal complaint.
If you are an Arkansas firearms-law practitioner
The opinion's most useful contribution is the explicit holding that the Little Rock Zoo qualifies as a "municipal park" for § 5-73-122 purposes despite being branded as a zoo. The AG anchors that holding in three things: physical location inside War Memorial Park, dual operation by Parks and Recreation and the Zoo Department, and the City's own ordinance (§ 22-211) listing zoological museums in its parks-and-recreation system. That reasoning is portable to similar facilities (botanical gardens, historic sites, recreation centers) sitting inside city park systems. It is also a useful authority on how the 2021 amendments (Acts 638 and 693) reshaped municipal-park carry rights.
If you are an Arkansas state legislator
The opinion shows how 2021 Acts 638 and 693 changed the on-the-ground regulatory landscape for municipal parks, but local governments are still posting old-style "no firearms" signs that exceed the new authority. If the legislature intends to give cities back some authority over recreational property like zoos, it will need to either narrow the § 5-73-122(a)(4) "facility" exclusion or add a specific § 5-73-306 carry restriction for zoological gardens.
Common questions
Q: Can I carry a loaded handgun openly into the Little Rock Zoo without a license?
A: According to the AG opinion, yes, in the open areas of the Zoo. The 2021 amendments to § 5-73-122 took municipal parks out of the "facility" definition, removing the bar on unlicensed open carry of loaded handguns in their open areas. You cannot open carry a loaded handgun into Zoo buildings; that remains barred under § 5-73-122. The City's current sign tells you no, but the AG says the sign exceeds the City's authority.
Q: I have a regular concealed-carry license. Can the City keep me out of the Zoo with a sign?
A: Yes, if the sign is compliant with § 5-73-306(18)(A). It must be at every entrance, clearly readable from at least 10 feet, and state that "carrying a handgun is prohibited." The current Zoo sign goes beyond that statutory format (it bars all firearms and all weapons with "no exceptions"), so it is not a textbook § 5-73-306(18)(A) sign. The City retains the authority to post a properly worded sign.
Q: I have an enhanced concealed-carry license. Does the sign apply to me?
A: According to the AG opinion, no. Section 5-73-306(18)(B)(iv) places E-CHCL holders carrying under § 5-73-322(g)–(h) outside subdivision (18)(A)'s reach on local-government property. The Zoo is local-government property. None of the four E-CHCL exceptions in § 5-73-122(a)(3)(D)(i)–(iv) (courtrooms, K–12 schools, prisons, § 5-73-325 firearm-sensitive areas) applies to the Zoo.
Q: Why is the Zoo treated as a "municipal park" when it is called a zoo?
A: Because the Little Rock Code of Ordinances § 22-211 lists zoological museums as part of the City's parks-and-recreation system, the Zoo physically sits inside War Memorial Park, and it operates under both the Parks and Recreation Department and the Zoo Department. The AG concluded those three facts together make the Zoo a "municipal park or similar recreational property" under § 5-73-122.
Q: Does this opinion let me carry into Zoo buildings (gift shop, restaurant, indoor exhibits)?
A: With an E-CHCL, yes, the opinion says you can. With unlicensed open carry, no. The opinion is explicit that unlicensed open carriers may carry in the open areas of municipal parks but not into buildings located within them.
Q: What happens if Little Rock keeps the sign up after this opinion?
A: The opinion is persuasive authority, not a binding court order. The City could ignore it and either keep the sign or amend it. Enforcement options for an aggrieved carrier include challenging an ejection or arrest in court (citing § 14-54-1411 preemption and this AG opinion as persuasive authority), or petitioning the AG or General Assembly for further action. AG opinions on preemption are often followed by litigation or legislative attention.
Q: Does Little Rock police authority change at the Zoo because of this opinion?
A: The opinion does not address officers' authority to investigate possible criminal conduct or address public-safety threats. It addresses only the legality of the no-firearms regulation. An officer who believes an individual is committing or about to commit an offense retains the authority to investigate, regardless of what this opinion says about the sign.
Background and statutory framework
Arkansas's local firearms preemption statute, A.C.A. § 14-54-1411, broadly bars cities, towns, and counties from regulating firearms unless state or federal law specifically authorizes the regulation. The statute reaches not just formal ordinances but any "attempt to regulate [firearms] in any other manner," including signs and policies. Cities have only the authority that state law gives them.
The general state ban on loaded firearms in publicly owned buildings or facilities, A.C.A. § 5-73-122, has two key carve-outs that drive municipal park carry:
- Subsection (a)(3)(D) lets E-CHCL holders carry concealed in publicly owned buildings or facilities, with four narrow exceptions: courtrooms or state administrative hearings (with crossover allowances under §§ 5-73-306(5)–(6)), K–12 schools and public daycares (with a § 5-73-122(a)(3)(C) crossover), Division of Correction or Community Correction facilities, and § 5-73-325 firearm-sensitive areas posted at the State Hospital, UAMS, or collegiate athletic events.
- Subsection (a)(4) excludes municipal parks, athletic fields, and similar recreational properties from the "facility" definition entirely. Act 693 of 2021 made that change. Combined with Act 638 of 2021's amendment to subsection (a)(3)(F), the effect is that unlicensed open carry of a loaded handgun in the open areas of municipal parks is no longer barred by § 5-73-122.
The licensed concealed carry framework runs through § 5-73-306 (places where concealed carry is prohibited) and § 5-73-322 (the enhanced license that lifts some of those prohibitions). Subdivision 18(A) gives "person[s] or entit[ies] exercising control" over a "place" the authority to bar standard CHCL holders by posting compliant signs. Subdivision 18(B)(iv) carves E-CHCL holders out of that authority on local-government property.
The Little Rock Zoo's status as a municipal park comes from three sources: physical location inside War Memorial Park; operation by both the Parks and Recreation Department and the Zoo Department; and the City's own ordinance, Little Rock Code § 22-211, which lists zoological museums among the City's parks-and-recreation facilities. Each of those points is documented in the opinion.
The opinion builds on two prior AG opinions issued just weeks before, both also dealing with carry in municipal parks: Ops. 2025-031 and 2025-051. The Zoo opinion applies the framework from those opinions to a specific City sign.
Citations and references
Arkansas statutes:
- A.C.A. § 14-54-1411, local firearms preemption
- A.C.A. § 5-73-122, loaded firearms in publicly owned buildings or facilities
- A.C.A. § 5-73-122(a)(3)(D) and (D)(i)–(iv), E-CHCL exception and its four carve-outs
- A.C.A. § 5-73-122(a)(3)(F), concealed-carry exception for municipal parks (as amended by Act 638 of 2021)
- A.C.A. § 5-73-122(a)(4), definition of "facility" excluding municipal parks (as amended by Act 693 of 2021)
- A.C.A. § 5-73-306, places where concealed carry is prohibited
- A.C.A. § 5-73-306(5)–(6), courtroom and administrative hearing crossovers
- A.C.A. § 5-73-306(18)(A), CHCL signage authority and statutory format
- A.C.A. § 5-73-306(18)(B)(iv), E-CHCL carve-out from signage authority on local-government property
- A.C.A. § 5-73-322(g)–(h), enhanced concealed carry license framework
- A.C.A. § 5-73-325: firearm-sensitive areas at State Hospital, UAMS, collegiate athletic events
Session Laws (Acts):
- Act 638 of 2021, amended § 5-73-122(a)(3)(F)
- Act 693 of 2021: amended § 5-73-122(a)(4) to exclude municipal parks from "facility"
Local ordinances:
- Little Rock, Ark., Code of Ordinances § 22-211: listing zoological museum as part of City parks-and-recreation system
Prior AG opinions:
- Ark. Att'y Gen. Op. 2025-031, carry in municipal parks
- Ark. Att'y Gen. Op. 2025-051: carry in municipal parks
Source
Original opinion text
BOB R. BROOKS JR. JUSTICE BUILDING
101 WEST CAPITOL AVENUE
LITTLE ROCK, ARKANSAS 72201
Opinion No. 2025-124
April 16, 2026
The Honorable Mark Johnson
State Senator
Post Office Box 241022
Little Rock, Arkansas 72223
Dear Senator Johnson:
I am writing in response to your request for an opinion on the legality of a sign prohibiting firearms
on the premises of the Little Rock Zoo, which you state is part of War Memorial Park. You
provided a photograph of the sign, which reads:
Notice: Carrying a handgun is prohibited on City property at any time. Carrying
any firearm or other deadly weapon on City property is also prohibited at any time.
THERE ARE NO EXCEPTIONS. You are subject to search. If weapons are found,
you will not be allowed to enter the property and must leave the area immediately.
Active and retired Little Rock Police Officers and Law Enforcement personnel
required to carry a firearm as a condition of their employment are not subject to this
prohibition. By order of the City Manager.
You note that this office recently issued Opinions 2025-031 and 2025-051, regarding carrying
weapons in municipal parks. In light of those opinions, you ask:
Is the sign posted on the premises of the Little Rock Zoo, which is a part of War
Memorial Park, a direct violation of A.C.A. § 14-54-1411?
RESPONSE
Yes, the sign posted on the premises of the Little Rock Zoo violates A.C.A. § 14-54-1411 because
it constitutes a regulation on firearms that is not fully authorized by state or federal law.
DISCUSSION
Under A.C.A. § 14-54-1411, a local unit of government (meaning a city, town, or county) is
prohibited from regulating or enacting any ordinance or regulation pertaining to "the ownership,
transfer, transportation, carrying, or possession of" firearms unless otherwise authorized by state
The Honorable Mark Johnson
State Senator
Opinion No. 2025-124
Page 2
or federal law.1 The broad scope of the statute preempts not only formal ordinances, but any
attempt to "regulate [firearms] in any other manner."
2
The sign, which is an "order by the City Manager," directs the public to disarm under threat of
search and ejection from the Zoo. This is plainly an attempt to regulate the carrying of firearms.
Thus, the sign violates § 14-54-1411 unless a specific state or federal law authorizes the City to
impose such a prohibition.
There are no federal laws authorizing the City of Little Rock to prohibit firearms within the Little
Rock Zoo. Turning to Arkansas law, A.C.A. § 5-73-122 generally prohibits carrying loaded
firearms in "publicly owned buildings or facilities." But Arkansas law exempts enhanced
concealed carry license ("E-CHCL") holders from this prohibition, subject to certain limited
exceptions. And because municipal parks are excluded from the definition of "facilities," a city
generally may not invoke § 5-73-122 to bar unlicensed open carry in the open areas of a municipal
park. As explained in Section II, the Little Rock Zoo constitutes a municipal park. These
exceptions are relevant to the Little Rock Zoo because it contains both open areas and enclosed
buildings. Yet neither exception is acknowledged in the City's sign prohibiting firearms on the
Zoo's premises. The City may, however, use a sign to exclude individuals holding a standard
concealed carry license ("CHCL") under A.C.A. § 5-73-306(18)(A). The scope of the two
applicable exceptions—and the limits of the City's authority to exclude CHCL holders with
signage—are explained below.
1. E-CHCL exception. The first exception is for individuals who possess a concealed carry
endorsement issued by the Division of Arkansas State Police under § 5-73-322(g), often referred
to as an E-CHCL. This endorsement is not a separate license; rather, it is an enhanced version of
the standard CHCL. Holders of an E-CHCL are allowed to carry a concealed handgun within
publicly owned buildings or facilities, with some exceptions, but none of those exceptions are
applicable to the Little Rock Zoo.3 Accordingly, holders of an E-CHCL may carry a loaded,
concealed handgun within the buildings inside the Little Rock Zoo and in the open areas of the
Zoo. The City of Little Rock violates § 14-54-1411 by preventing E-CHCL holders from entering
the Zoo.
1 A.C.A. § 14-54-1411(a)–(b)(1)(A)(i).
2
Id. § 14-54-1411(b)(1)(A).
3A.C.A. § 5-73-122(a)(3)(D) (allowing E-CHCL holders to carry a concealed handgun within publicly owned
buildings or facilities unless the place is "(i) A courtroom or the location of an administrative hearing conducted by a
state agency, except as permitted by § 5-73-306(5) or § 5-73-306(6); (ii) A public school kindergarten through grade
twelve (K–12), a public prekindergarten, or a public daycare facility, except as permitted under subdivision (a)(3)(C)
of this section; (iii) A facility operated by the Division of Correction or the Division of Community Correction; or (iv)
A posted firearm-sensitive area, as approved by the Division of Arkansas State Police under § 5-73-325, located at (a)
The Arkansas State Hospital; (b) The University of Arkansas Medical Sciences; or (c) A collegiate athletic event[.]").
The Honorable Mark Johnson
State Senator
Opinion No. 2025-124
Page 3
2. Unlicensed open carry exception. The second relevant exception is for individuals who openly
carry a handgun without a license. This office has previously opined that individuals who open
carry without a license may lawfully carry a loaded handgun into any open area of a municipal
park, but they may not carry into any buildings located within a municipal park.4 The General
Assembly amended § 5-73-122(a)(3)(F) and § 5-73-122(a)(4) to effectively remove the
prohibition on handguns within municipal parks and similar recreational properties, with some
exceptions.5 These amendments apply to the Little Rock Zoo because the Zoo constitutes a
municipal park, as explained below.
The Zoo is physically located within War Memorial Park, and it operates under the authority of
two City of Little Rock Departments: the Parks and Recreation Department and the Zoo
Department.6 The Little Rock Code of Ordinances states:
The city of Little Rock shall maintain an efficient parks and recreation system,
which among other things, shall include parks, open space, athletic fields, tennis
facilities, swimming pools, a zoological museum, fitness centers, golf courses,
senior adult centers, and other facilities dedicated to enhancing the quality of life
for the citizens and visitors to the city.7
Since the City of Little Rock includes the Zoo among its other parks and recreational buildings or
facilities, it constitutes a municipal park or similar recreational property within the meaning of
§ 5-73-122. Thus, the exemption allowing unlicensed individuals to open carry within the open
areas of municipal parks applies. The City's sign violates § 14-54-1411 by prohibiting individuals
who open carry from entering the Zoo's open areas.
3. CHCL signage authority. Under A.C.A. § 5-73-306(18)(A)(i), a "person or entity exercising
control" over a "place" may bar standard CHCL holders from carrying a concealed handgun in
that place. The statute authorizes the controlling entity, which may include a local unit of
government, to post a sign at each entrance that is clearly readable from at least ten feet and states
that "carrying a handgun is prohibited."8 When a sign complies with subdivision 18(A), a CHCL
holder may be lawfully excluded from carrying a concealed handgun at that location.
4 Ark. Att'y Gen. Ops. 2025-051, 2025-031.
5 A.C.A. § 5-73-122(a)(3)(F), as amended by Act 638 of 2021 (adding an exception for concealed carry license holders
to carry within municipal parks except at athletic fields during athletic events or practices); A.C.A. § 5-73-122(a)(4),
as amended by Act 693 of 2021 (modifying the definition of "facility" by replacing "means" with "does not mean,"
effectively removing municipal parks, athletic fields, and similar recreational properties from the definition of
facility); Ark. Att'y Gen. Ops. 2025-051, 2025-031.
6 Little Rock, Ark., Code of Ordinances § 22-211.
7
Id.
8 A.C.A. § 5-73-306(18)(A)(i)–(ii).
The Honorable Mark Johnson
State Senator
Opinion No. 2025-124
Page 4
This signage authority is narrowly drawn. It applies only to CHCL holders carrying concealed
handguns. It does not create a free-standing power for local governments to ban any firearm on
government property. Notably, A.C.A. § 5-73-306(18)(B)(iv) provides that subdivision 18(A)
"does not apply" to a "place owned, controlled, or operated by a local unit of government" when
the person is carrying under the E-CHCL provisions in A.C.A. § 5-73-322(g) and (h). E-CHCL
holders are subject only to the exceptions in A.C.A. § 5-73-122(a)(3)(D)(i)–(iv) and to the separate
restriction applicable to alcohol-licensed premises.9 As a result, even when a city uses compliant
signage to exclude standard CHCL holders, it generally may not use that same signage to exclude
E-CHCL holders from local-government property unless one of those statutory carve-outs applies.
4. Summary. Applied here, the sign posted by the City of Little Rock at the Little Rock Zoo
violates state law. By attempting to ban all firearms on "City property" with "no exceptions," the
City has enacted a regulation that exceeds its statutory authority under § 14-54-1411. The Zoo
constitutes a municipal park where state law preserves the right of E-CHCL holders to enter
buildings and open areas within the Zoo. In addition, the sign fails to acknowledge the rights of
individuals who open carry without a license to carry a loaded handgun in the open areas of
municipal parks, including the Zoo. Thus, the sign, as currently worded, constitutes a violation of
§ 14-54-1411. The City must revise the sign to bring it into compliance with §§ 14-54-1411, 5-73-
122, and 5-73-306.
Assistant Attorney General Justin Hughes prepared this opinion, which I hereby approve.
Sincerely,
TIM GRIFFIN
Attorney General
9 A.C.A. § 5-73-306(18)(b)(iv); A.C.A. § 5-73-322(g)–(h); A.C.A. § 5-73-122(a)(3)(D)(i)–(iv).