Justia Arkansas Supreme Court Opinion Summaries

A class of police officers and firefighters employed by the City of Conway brought a class-action complaint alleging that the City breached its employment contract with them when it failed to allocate sales tax revenues to fund salary increases. The circuit court certified the class action, finding that there were overarching, common questions that could efficiently be determined on a class-wide basis. The Supreme Court affirmed the circuit court’s class-certification order, holding that the circuit court did not abuse its discretion when if found the prerequisites of a class action. View "City of Conway v. Shumate" on Justia Law

Guy Hendrix, the decedent in this case, worked for Alcoa Inc. for nearly thirty years. After he retired, Hendrix filed a claim against Alcoa for workers’ compensation benefits, alleging that he was exposed to asbestos during the course of his employment, leading to his diagnosis of an asbestos-related cancer. An administrative law judge found that the claim was time-barred because it was not filed within three years of his last date of the injurious exposure. After Hendrix died, his estate initiated this wrongful-death and survival action against Alcoa. Alcoa moved to dismiss the claims, asserting that the circuit court lacked jurisdiction because the claims fell within the exclusive-remedy provision of the Workers’ Compensation Act. The circuit court agreed and dismissed the claims against Alcoa with prejudice. The estate appealed, arguing that because the statute of repose extinguished Hendrix’s remedy under the Act before it accrued, the exclusive-remedy provision no longer applied. The Supreme Court affirmed, holding that the claim falls within the coverage formula of the Act, even though Hendrix was ultimately denied recovery on the ground that the claim was time-barred. View "Hendrix v. Alcoa Inc." on Justia Law

Defendants in this case included a Union, a subsidiary of the Union, and John Does (collectively, Defendants) who conducted demonstrations to help current and former Walmart employees on issues related to their employment. Walmart filed a complaint in the circuit court alleging trespass and seeking injunctive and declaratory relief. The circuit court found that Walmart had met the requirements for a permanent injunction and a declaratory judgment. The injunction prohibited any non-employee defendant from engaging in any non-shopping activities on Walmart’s private property in Arkansas, and the circuit court declared that Defendants’ entrance onto Walmart private property for non-shopping purposes constituted a trespass. The Supreme Court affirmed as modified, holding (1) the National Labor Relations Act does not preempt Walmart’s trespass lawsuit; (2) the circuit court did not err in enjoining Defendants from entering parking lots and sidewalks that Walmart does not hold the right to exclusively possess; and (3) the injunction and declaration are overly broad as to their scope in that they prohibit “all non-shopping activity,” and the circuit court’s order is modified to limit the scope of the order to those activities that were proven by Walmart to cause irreparable harm. View "United Food & Commercial Workers International Union v. Wal-Mart Stores Inc." on Justia Law

Eugene Butler brought this suit against the Board of Trustees of the University of Arkansas, alleging that the University violated the Arkansas Whistle-Blower Act (AWBA) upon terminating Appellant from his job as a police officer at the University of Arkansas at Pine Bluff. The University filed a motion to dismiss pursuant to Ark. R. Civ. P. 12(b)(6), arguing that Butler’s complaint failed to state a cause of action that was not barred by sovereign immunity. The circuit court denied the motion. The Supreme Court reversed and dismissed the complaint, holding that the University was entitled to sovereign immunity because the complaint failed to state a factual basis for Butler’s claim under the AWBA. View "Johnson v. Butler" on Justia Law

Appellant Gerber Products Company d/b/a Nestle Infant Nutrition d/b/a Nestle Nutrition USA d/b/a Nestle Nutrition USA-Infant Nutrition d/b/a Nestle Nutrition USA-Performance Nutrition (“Gerber”) appealed a circuit court order granting partial summary judgment in favor of appellees in their case alleging Gerber’s liability for failure to pay certain overtime wages in violation of the Arkansas Minimum Wage Act (“AMWA”). Appellees were employed by Gerber at its baby food processing and manufacturing facility located in Fort Smith. Specifically, the employees alleged that Gerber failed to compensate the employees for their time spent donning and doffing clothing and protective gear, sanitizing clothing and equipment, washing their hands, and walking to and from their work stations. Both parties filed motions for summary judgment. The employees argued that there was no genuine issue of material fact that Gerber did not pay the employees for their time spent donning, doffing, washing, walking, and waiting. Both parties’ motions for summary judgment were initially denied. However, a hearing was held on the cross-motions for summary judgment, and the circuit court orally announced from the bench that it was changing its earlier order in favor of the employees, finding that the AMWA required Gerber to “treat the time required by employees to complete the mandatory donning and doffing activities at issue in this lawsuit as compensable work time, notwithstanding any contrary custom or practice under a collective bargaining agreement applicable to those employees or any express agreement.” On appeal, Gerber argued that the circuit court erred in granting the employees’ motion for partial summary judgment. Finding no reversible error, the Supreme Court affirmed the grant of partial summary judgment. View "Gerber Prods. Co. v. Hewitt" on Justia Law

Marilyn Worsham worked for a nonprofit agency and was later transferred to a host agency, at which time her pay was reduced. Worsham filed for unemployment benefits, but the Department of Workforce Services denied the claim. The Appeal Tribunal affirmed. The Board of Review affirmed and adopted the Appeal Tribunals ruling, finding that Worsham did not meet the wage requirements under Ark. Code Ann. 11-10-507(5)(A) for establishing a claim. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Board did not err in refusing to accept additional evidence at another hearing; and (2) the Board did not err in ruling that Worsham did not meet the wage requirements for establishing an unemployment-benefit claim. View "Worsham v. Bassett" on Justia Law

Marilyn Worsham worked for a nonprofit agency and was later transferred to a host agency, at which time her pay was reduced. Worsham filed for unemployment benefits, but the Department of Workforce Services denied the claim. The Appeal Tribunal affirmed. The Board of Review affirmed and adopted the Appeal Tribunals ruling, finding that Worsham did not meet the wage requirements under Ark. Code Ann. 11-10-507(5)(A) for establishing a claim. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the Board did not err in refusing to accept additional evidence at another hearing; and (2) the Board did not err in ruling that Worsham did not meet the wage requirements for establishing an unemployment-benefit claim. View "Worsham v. Bassett" on Justia Law

Appellees in this case were hourly, non-nursing employees of Arkansas Department of Veterans Affairs d/b/a Arkansas Veterans Home and Fayetteville Veterans Home (ADVA). Appellees sought class certification alleging that ADVA violated the Arkansas Minimum Wage Act by failing to pay Appellees for overtime hours worked. The circuit court found that class certification was appropriate as to claims alleging that ADVA automatically deducted thirty minutes daily from Appellees’ hours worked to account for meal breaks even though they were regularly required to work during their meal breaks. ADVA appealed. The Supreme Court reversed, holding that because Appellees’ claims were highly individualized, the circuit court abused its discretion in certifying the class action. Remanded with instructions to decertify the class. View "Ark. Dep't of Veterans Affairs v. Mallett" on Justia Law

Plaintiffs were registered nurses, licensed practical nurses, and certified nursing assistants who worked for the Arkansas Department of Veterans Affairs (ADVA) as hourly employees. Plaintiffs brought this action alleging violations of the Arkansas Minimum Wage Act for failing to pay them for all overtime hours worked. Plaintiffs sought class certification. After a hearing, the circuit court granted class certification. ADVA appealed, arguing that the circuit court abused its discretion in certifying the class. The Supreme Court affirmed, holding that the circuit court did not abuse its discretion in its findings regarding the requirements of commonality, predominance, and superiority. View "Ark. Dep't of Veterans Affairs v. Okeke" on Justia Law

Mason Mauldin, an employee of Central Flying Service, Inc. (CFS), was killed when the plane he was flying during the course of his employment crashed. Mauldin’s estate (the Estate) filed a wrongful-death complaint against CFS and Mauldin’s supervisor (collectively, Petitioners), alleging intentional misconduct, respondeat superior, wrongful death, and survival. The Estate then amended its complaint to raise a claim challenging the constitutionality of the Arkansas Workers’ Compensation Act. Petitioners moved to dismiss the Estate’s complaint because of a lack of subject-matter jurisdiction, asserting that the Estate’s exclusive remedy was provided by the Act. The circuit court denied the motion to dismiss. Petitioners petitioned the Supreme Court for a writ of prohibition to prohibit the circuit court from continuing to exercise jurisdiction over the complaint. The Supreme Court granted the petition, holding that the circuit court was wholly without jurisdiction over the Estate’s complaint, as (1) Petitioners were entitled to immunity from tort liability for the Estate’s claims against them; and (2) in order to challenge the constitutionality of the act, the Estate must demonstrate that the Act applies to it, and the Arkansas Workers’ Compensation Commission has exclusive, original jurisdiction to determine the applicability of the Act. View "Central Flying Serv. Inc. v. Circuit Court" on Justia Law