Justia Contracts Opinion Summaries

The Supreme Court affirmed the order of the circuit court affirming amended integration orders entered by the Arkansas Oil & Gas Commission (AOGC), holding that the AOGC did not exceed its statutory authority in granting SWN Production, LLC's (SWN) request to reduce the royalty payable under Appellants' oil and gas leases when the lessees elected to go "non-consent."On appeal, Appellants argued that the AOGC's actions were both ultra vires and arbitrary and capricious. The Supreme Court affirmed, holding (1) while there is no statutory provision specifically stating that the AOGC may reduce the royalty rate contained in a lease, there is also no statutory language expressly stating that the consenting parties - such as SWN - are responsible for payment of royalties when an uncommitted leasehold working-interest owner elects to go non-consent; and (2) the AOGC's orders were neither ultra vires nor arbitrary and capricious. View "Hurd v. Arkansas Oil & Gas Commission" on Justia Law

The Supreme Court reversed the judgment of the circuit court denying Appellants' motion to compel arbitration pursuant to the arbitration agreement contained in the parties' installment-sales contract, holding that the contract was supported by mutual obligations and plainly stated that Appellants did not waive arbitration by obtaining a monetary judgment in the small claims division of district court.Appellees purchased a vehicle with an installment-sales contract but failed to make their scheduled payments. Appellees voluntarily surrendered the vehicle, the vehicle was sold, and Appellees' account was credited. Appellants filed a complaint in the small claims division seeking payment for the remaining balance, and the district court entered judgment against Appellees. Appellees appealed, counterclaimed based on usury and Uniform Commercial Code violations, and sought class certification. Appellants sought to compel arbitration. The circuit court denied the motion, concluding that the arbitration agreement at issue lacked mutuality of obligation and that Appellants waived the right to arbitrate by first proceeding in district court. The Supreme Court reversed, holding (1) the arbitration agreement was valid; and (2) Appellants did not waive arbitration by first seeking monetary relief in district court. View "Jorja Trading, Inc. v. Willis" on Justia Law

In this appeal from the reinstatement of Plaintiff's bench-trial judgment that the Supreme Court had earlier set aside the Supreme Court reversed the judgment of the circuit court ruling that Defendant's right to a jury trial had been obviated by new legislation, holding that Defendant was entitled to a jury trial.Plaintiff asserted his right to a jury trial, but because there was a jury trial waiver clause in the loan agreement that was the subject of the litigation the circuit court struck Plaintiff's jury trial demand. The court proceeded to enter judgment against Plaintiff after a bench trial. On appeal, the Supreme Court held that "pre-dispute contractual jury waivers are unenforceable under the Arkansas Constitution" and reversed and remanded the case for a jury trial. Instead, the circuit court applied Act 13 of 2018, which the General Assembly passed after the mandate issued, and ruled that Plaintiff was not entitled to a jury trial on his claims. The Supreme Court reversed, holding that the circuit court erred in ruling that Act 13 applied in this case. View "Tilley v. Malvern National Bank" on Justia Law

The Supreme Court affirmed the order of the circuit court granted summary judgment in favor of Shelter Mutual Insurance Company on Plaintiffs' claim arising from medical expenses they incurred following an automobile accident, holding that the trial court did not err in granting summary judgment.On appeal, Plaintiffs argued that the language in the relevant insurance policy was ambiguous or, in the alternative, the policy language was against public policy and should be declared void. The Supreme Court affirmed, holding (1) the applicable policy language was not ambiguous, and the policy was not against the public policy of the State of Arkansas; and (2) Plaintiffs' argument that the trial court erred in denying their motion in limine was moot. View "Crockett v. Shelter Mutual Insurance Co." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the circuit court denying motions to compel arbitration of a class-action complaint filed by Appellees, holding that Appellants failed to meet their burden of proving a valid and enforceable arbitration agreement with respect to certain agreements but that Appellants met their burden to prove the validity of the remainder of the arbitration agreements.Appellees filed a class-action complaint against Appellants, a nursing home and related entities, alleging that Appellants had breached their admission and provider agreements, violated the Arkansas Deceptive Trade Practices Act, committed negligence and civil conspiracy, and had been unjustly enriched. Appellants' filed four motions to compel arbitration with respect to ten class members/residents. The circuit court denied the motions. The Supreme Court affirmed in part and reversed in part, holding (1) certain arbitration agreements contained deficiencies that prevented Appellants from meeting their burden of proving a valid and enforceable arbitration agreement; and (2) Appellants met their burden to prove the validity of the remainder of the arbitration agreements not already discussed. View "Robinson Nursing & Rehabilitation Center, LLC v. Phillips" on Justia Law

The Supreme Court affirmed the order of the circuit court granting Plaintiffs' motion for class certification in this action alleging that Defendant, which leased with Plaintiffs to drill and sell hydrocarbons from the leased property, improperly suspended royalty payments, holding that the requirements of numerosity and superiority were met.The complaint alleged that the royalty payments were suspended in an effort by Defendant to recoup improper deductions. Plaintiffs moved for class certification, which the trial court granted. Defendant appealed, arguing that Plaintiffs failed to satisfy the numerosity and superiority requirements. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in determining that the numerosity and superiority requirements were satisfied in this case. View "Stephens Production Co. v. Mainer" on Justia Law

In this case in which Debbie Worsham was awarded damages on her breach of contract action the Supreme Court affirmed the judgment of the circuit court denying Worsham's motion for attorney's fees and costs and Worsham's motion for reconsideration, holding that Worsham's motion for attorney's fees was untimely.On appeal, Worsham argued that she was entitled to attorney's fees pursuant to Ark. Code Ann. 16-22-308 and that the circuit court erred in denying her motion for attorney's fees because it was timely under Ark. R. Civ. P. 54(e). The Supreme Court affirmed the circuit court's denial of Worsham's motion for attorney's fees, holding (1) the circuit court correctly found that the attorney's fees motion was untimely; and (2) Worsham's argument that she was entitled to attorney's fees under section 16-22-308 was without merit. View "Worsham v. Day" on Justia Law

The Supreme Court affirmed the circuit court's order granting summary judgment in favor of Appellee in this contract dispute, holding that the circuit court did not err in concluding that Appellee's loan to Appellant was payable on demand because the loan agreement did not have a maturity date.After Appellee demanded repayment of his loan and Appellant refused Appellee sued for repayment of the loan and attorney's fees. The circuit court granted Appellee's summary judgment motion, concluding that because the loan did not have a maturity date it was payable on demand. The court also awarded Appellee attorney's fees. The court of appeals reversed, holding that genuine issues of material fact existed as to whether the loan agreement was an on-demand contract. The Supreme Court vacated the opinion of the court of appeals and affirmed the judgment of the circuit court, holding (1) because the loan agreement was silent as to the maturity date, it was payable on demand; and (2) the attorney's fees and costs award was proper. View "Miracle Kids Success Academy, Inc. v. Maurras" on Justia Law

A jury found for Plaintiff on her claim for breach of contract and on her promissory-estoppel claim. The jury rendered verdicts against Defendants on their counterclaims. Defendants filed a motion for judgment notwithstanding the verdict (JNOV) or for a new trial. The trial court granted the motion, concluding that the jury verdicts were improper and inconsistent and that they should be set aside in favor of granting a new trial. The circuit court denied Plaintiff’s motion to reconsider. Plaintiff appealed. The Supreme Court dismissed the appeal for lack of appellate jurisdiction because Defendants’ motion for JNOV or a new trial was filed prior to the entry of the judgment. Therefore, the circuit court’s order granting a new trial was a nullity, and the posttrial motion was deemed denied thirty days after its filing date. Because neither party filed a notice of appeal after the judgment was entered the court had no timely or effective notice of appeal from the disposition of the posttrial motion. View "Worsham v. Day" on Justia Law

The circuit court determined that appropriations made by ordinances or resolutions of the cities of Little Rock and North Little Rock (Appellants) to the cities’ chambers of commerce and related economic development entities were in violation of article 12, section 5 of the Arkansas Constitution. The court concluded that Appellants had appropriated city funds to private corporations using “service contracts” that violated article 12, section 5 and were invalid due to lack of consideration and absence of benefits to the taxpayers. The court permanently enjoined Appellants from passing such ordinances or resolutions. The Supreme Court remanded the case to the circuit court with instructions to lift the injunction and dismiss Appellees’ complaint, holding that an amendment to article 12, section 5 rendered the basis for the circuit court’s injunction moot. View "Stodola v. Lynch" on Justia Law