Justia Arkansas Supreme Court Opinion Summaries

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

Wal-Mart Stores, Inc. and other related business entities (collectively, Wal-Mart) sought injunctive relief after the United Food and Commercial Workers International Union, Organization United for Respect at WlMart (the union) undertook a campaign of “flash mob” protests at Wal-Mart properties in northwest Arkansas. The circuit court granted a temporary restraining order, which the circuit court converted into a preliminary injunction by stipulation of the parties. The union subsequently filed a motion to dissolve or modify the preliminary injunction. The circuit court denied the motion. The Supreme Court affirmed, holding that the circuit court did not err in denying the motion to dissolve or modify the preliminary injunction. View "United Food & Commercial Workers Int'l Union v. Wal-Mart Stores, Inc." on Justia Law

Gloria Daniel was fired from her position as a registered nurse at the Arkansas State Hospital thirteen months after she reported to Charles Smith, the hospital’s administrator, that a patient’s death was attributable to abuse or neglect on the part of the hospital. Daniel filed suit, asserting claims under the Arkansas Whistle-Blower Act, the Arkansas Civil Rights Act, and federal law, naming as Defendants Smith in his individual and official capacities, and Betty Mains in her official and individual capacities as the hospital’s assistant administrator. The circuit court concluded that Daniel’s claim for retaliation was not barred by sovereign immunity and that Defendants were not entitled to qualified immunity. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the circuit court (1) did not err in denying Defendants’ motion for summary judgment based on sovereign immunity; and (2) erred in denying Defendants’ motion for summary judgment to dismiss the individual-capacity claims based on qualified statutory immunity grounds. View "Smith v. Daniel" on Justia Law

Jess Clayton was working at a nuclear facility owned and operated by Entergy Arkansas, Inc. and Entergy Operations, Inc. (collectively, Entergy) when he was injured by a falling steel beam. Clayton was an employee of Precision Surveillance Corporation at the time of the accident. Clayton sued Entergy and DP Engineering, Ltd., which was retained to provide engineering advice regarding the crane. Entergy and DP both filed motions to dismiss. The circuit court denied the motions. Entergy and DP petitioned for writ of prohibition, claiming that the circuit court was precluded from exercising jurisdiction over Clayton’s claims because jurisdiction lay exclusively with the Arkansas Workers’ Compensation Commission to determine the applicability of the Workers’ Compensation Act. The Supreme Court granted the petitions,, holding that the circuit court acted without jurisdiction in deciding whether an employer-employee relationship existed between Walter, Entergy, and DP, as these determinations lay exclusively with the Commission. View "Entergy Ark. Inc. v. Pope County Circuit Court" on Justia Law

Entergy Arkansas, Inc. and Entergy Operations, Inc. (collectively, Entergy), the owner and operator of a nuclear plant, contracted with Precision Surveillance Company (PSC) to provide civil engineers for a project. Wade Walters, a PSC employee, died as the result of an accident at the plant. Plaintiff filed a personal-injury action in the circuit court, naming several defendants, including Walters, Entergy, and DP Engineering, Ltd. Co. Entergy filed a motion to dismiss for lack of subject-matter jurisdiction, asserting immunity under the exclusive-remedy provisions of the Arkansas Workers’ Compensation Act, or, in the alternative, a motion to stay pending a review by the Arkansas Workers’ Compensation Commission. DP also filed a motion to dismiss. The circuit court denied the motions to dismiss. Entergy and DP filed petitions for writ of prohibition, contending that the circuit court was wholly without jurisdiction to determine the applicability of the Act to the facts of this case. The Supreme Court granted the petitions,, holding that the circuit court acted without jurisdiction in deciding whether an employer-employee relationship existed between Walter, Entergy, and DP, as these determinations lay exclusively with the Commission. View "Entergy Ark., Inc. v. Pope County Circuit Court" on Justia Law

In 2012, Appellant, clerk for the City of Harrisburg, filed a complaint and petition for writ of quo warranto seeking to compel the City to pay her wages due for the joint position of city clerk/treasurer and alleging that the present treasurer of the City was occupying the office without legal authority. The City filed a motion for summary judgment, asserting that Appellant, as city clerk, was not the successor to the former office of city clerk/treasurer and was therefore not entitled to any additional wages. The circuit court denied the City’s summary judgment motion and then dismissed Appellant’s complaint with prejudice, concluding that the ordinance relied upon by Appellant did not recognize and fund the combined office of city clerk/treasurer. The Supreme Court affirmed, holding that the circuit court did not err in finding that the ordinance did not join the offices of city clerk and treasurer so as to establish a combined office of city clerk/treasurer. View "King v. City of Harrisburg" on Justia Law

Appellant was injured while working for Employer. Following the accident, a drug test on Appellant came back positive. Appellant sought workers’ compensation benefits. An administrative law judge found that Appellant was entitled to benefits, concluding that he met his burden of proving that his accidental work incident was not substantially occasioned by the use of drugs. The Arkansas Workers’ Compensation Commission reversed, determining that Appellant did not rebut the presumption that his accident was substantially occasioned by his use of illegal drugs. The Supreme Court reversed and remanded to the Commission for a determination of benefits, holding that substantial evidence did not support the Commission’s finding that Appellant failed to rebut the presumption by a preponderance of the evidence. View "Prock v. Bull Shoals Boat Landing" on Justia Law

Appellant was injured at work and taken to the hospital, where he tested positive for marijuana. The Arkansas Workers’ Compensation Commission denied Appellant’s claim for benefits based on its finding that, after the accident, Appellant tested positive for illegal drugs and thatAppellant failed to rebut the statutory presumption that the accident was substantially occasioned by his drug use. The Supreme Court reversed and remanded the Commission’s decision, holding that substantial evidence did not support the finding that Appellant failed to rebut the presumption that his accident was not substantially occasioned by his use of illegal drugs. View "Edmisten v. Bull Shoals Landing" on Justia Law

Mike Burcham filed an amended complaint against the Board of Trustees of the University of Arkansas for wrongful discharge. After the circuit court denied the Board’s motion to dismiss based on sovereign immunity, the Board sought extraordinary writs of mandamus, prohibition, and certiorari directed to the Circuit Court of Crawford County to stop the court from proceeding further on the complaint based on lack of venue. The Supreme Court also decided on the day of this opinion, in a separate interlocutory appeal, that the Board was entitled to sovereign immunity. Because of the Court’s conclusion that the Board was indeed entitled to sovereign immunity, the case against the Board was dismissed and the instant petition for extraordinary writs was therefore moot. View "Bd. of Trs. v. Crawford County Cir. Court" on Justia Law

Mike Burcham filed an action against the University of Arkansas and others, claiming that he was wrongfully terminated. The University filed an amended motion to dismiss, arguing that Burcham’s complaint was barred by sovereign immunity. The circuit court denied the motion, concluding that an allegation in Burcham’s complaint that the University failed to follow a grievance procedure outlined in the employee handbook was sufficient to waive the University’s sovereign immunity. The Supreme Court reversed, holding that none of the exceptions to sovereign immunity were applicable to the instant case, and therefore, the circuit court erred in denying the University’s amended motion to dismiss. View "Bd. of Trs. v. Burcham" on Justia Law