Justia Arkansas Supreme Court Opinion Summaries

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

Randeep Mann targeted Dr. Trent Pierce in a bombing. Dr. Pierce was seriously injured in the bombing. Mann was subsequently convicted of using and conspiring to use a weapon of mass destruction against a person within the United States, among other charges. Dr. Pierce and Melissa Pierce subsequently brought tort claims against Mann. The circuit court granted the Pierces’ motion for partial summary judgment as to liability, concluding that offensive collateral estopped could be applied as a result of Mann’s criminal convictions. After a trial on the issue of damages, the jury awarded a total of $122,500,000 in compensatory and punitive damages to the Pierces. The Supreme Court affirmed, holding that the circuit court did not err in applying the doctrine of offensive collateral estoppel in granting partial summary judgment on liability in favor of the Perces. View "Mann v. Pierce" 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

After Tony Havner was injured in a motorcycle accident involving an overhead communications cable, Havner and his wife, Tina Havner, filed a negligence action against Northeast Arkansas Electric Cooperative (NAEC) and other defendants. The circuit court granted summary judgment in favor of NAEC. Havner subsequently filed a motion for entry of judgment and an Ark. R. Civ. P. 54(b) certificate with the circuit court. The court entered a judgment and a Rule 54(b) certificate, which was stamped as ‘presented’ and ‘recorded.’ The case was then submitted to the court of appeals. The court of appeals dismissed the appeal without prejudice for lack of a final order, concluding that because the judgment and 54(b) certificate was recorded but never filed, it was not entered as required by court rules. The Supreme Court vacated the court of appeals opinion, holding that, in light of In re Administrative Order No. 2(b)(2), the circuit court’s summary-judgment order was a final, appealable order. Remanded. View "Havner v. Northeast Arkansas Electric Cooperative" on Justia Law

Appellant entered into a contract with Appellee specifying that Appellee would provide Appellant with software development services. Appellant later terminated the parties’ contract based on its alleged belief that three separate provisions of the parties’ agreement entitled it to terminate the contract. Appellee filed this breach-of-contract action against Appellant. Appellant counterclaimed for breach of contract and tortious interference with contractual relationship or business expectancy. A jury returned a verdict in favor of Appellee and awarded $150,000 in compensatory damages. Appellant appealed the judgment and Appellee cross-appealed from the circuit court’s postjudgment denial of its motion for attorneys’ fees and costs. The Supreme Court affirmed on appeal and reversed and on cross-appeal, holding (1) substantial evidence supported the jury’s breach-of-contract verdict; and (2) because the circuit court did not adequately explain its denial of attorneys’ fees, the case must be remanded for the limited purpose of making findings to allow for appellate review of the fee decision. View "Ark. Realtors Ass'n v. Real Forms LLC" on Justia Law

William Curtis was injured when Michael Lemna drove a golf cart over a retaining wall during a game of golf scheduled as part of a sales meeting in Arkansas. Both Curtis and Lemna were employees of Dial Corporation headquartered in Arizona at the time of the accident. Curtis sued Lemna in Benton County Circuit Court alleging negligence. The circuit court dismissed the case without prejudice for lack of jurisdiction until the Arkansas Workers’ Compensation Commission could determine the applicability of Arkansas’ workers’ compensation laws. Curtis subsequently requested a hearing before the Commission. The Commission concluded that Curtis and Lemna were acting within the scope of their employment at the time of the accident and that co-employee immunity was extended to Lemna acting as the employer providing a safe work environment. The Supreme Court affirmed, holding (1) the Commission had jurisdiction over this case; (2) the Commission’s decision that Curtis’s injury occurred within the scope of his employment was supported by substantial evidence; and (3) the Commission’s decision that Lemna was entitled to immunity was supported by substantial evidence.View "Curtis v. Lemna" on Justia Law

Plaintiff filed an amended complaint against Defendants, alleging breach of contract, misappropriation of trade secrets, tortious interference with a contract and business expectancy, and civil conspiracy. The circuit court granted Defendants’ motion to dismiss all four causes of action, concluding that Plaintiff failed to plead sufficient facts upon which relief could be granted. After Plaintiff filed an amended complaint asserting the same four causes of action, the circuit court again dismissed the complaint with prejudice under Ark. R. Civ. P. 12(b)(6). The Supreme Court (1) affirmed the part of the court’s second order dismissing with prejudice the breach-of-contract claim; but (2) reversed and remanded the parts of the order dismissing with prejudice Plaintiff’s remaining claims, as the claims went beyond mere conclusions and sufficiently stated facts upon which relief could be granted. View "The Ballard Group, Inc. v. BP Lubricants USA, Inc." on Justia Law

Susan and David Conrad purchased a home constructed by J-McDaniel Construction Company (McDaniel) and later discovered defects in the home. The Conrads sued McDaniel. McDaniel filed a third-party complaint against three subcontractors (collectively, Appellees). The subcontractors then filed cross-claims against each other seeking contribution, indemnity and apportionment of fault. The Conrads settled their claims against McDaniel. The circuit court ultimately dismissed McDaniel’s third-party claims against Appellees. The Supreme Court reversed, holding that unresolved issues of fact remained regarding whether McDaniel had a right of indemnity against Appellees under the facts of this case. View "J-McDaniel Constr. Co. v. Dale E. Peters Plumbing Ltd." on Justia Law