City of Rogers v. Powell

2024 Ark. App. 415, 698 S.W.3d 390
CourtCourt of Appeals of Arkansas
DecidedSeptember 11, 2024
StatusPublished

This text of 2024 Ark. App. 415 (City of Rogers v. Powell) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
City of Rogers v. Powell, 2024 Ark. App. 415, 698 S.W.3d 390 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 415 ARKANSAS COURT OF APPEALS DIVISION I No. CV-23-380

THE CITY OF ROGERS Opinion Delivered September 11, 2024 APPELLANT APPEAL FROM THE BENTON V. COUNTY CIRCUIT COURT [NO. 04CV-20-1361] ABIGAIL POWELL, TRUSTEE OF THE ABIGAIL RUTH POWELL HONORABLE XOLLIE DUNCAN, REVOCABLE TRUST U/D JUDGE NOVEMBER 15, 2001 APPELLEE REVERSED

N. MARK KLAPPENBACH, Judge

The City of Rogers appeals the denial of its motion for summary judgment in which

the City sought immunity from litigation. This interlocutory appeal is permitted by Ark. R.

App. P.–Civ. 2(a)(10) (2023). We reverse.

This litigation stems from a drainage problem. Arkansas Athletes Outreach (AAO)

intended to purchase approximately eleven acres on South Dixieland Road in Rogers and

planned to build a sports complex on the property. Before purchasing the property, AAO

submitted stormwater drainage plans with the City in February 2019. The plans were

rejected, and the City responded with several issues that needed to be addressed. AAO

purchased the property in May 2019. AAO’s engineer resolved the issues and resubmitted

a revised drainage plan in July 2019, which the City accepted because it complied with the City’s stormwater drainage manual. The City’s planning commission also approved AAO’s

large-scale development plan.

In June 2020, Abigail Powell, as trustee of the trust that owned approximately five

acres immediately south of the AAO property, filed a lawsuit against the City and AAO. The

five acres has a 3,324-square-foot residence, a 3,000-square-foot shop building, and animal

pens. Powell alleged that AAO had removed almost all the vegetation from its property and

installed drainage pipes that directed stormwater to flow across the Powell property. Powell

claimed that the AAO drainage system was not compliant with the city’s stormwater drainage

requirements, focusing on the flaws in AAO’s February 2019 plans that the City had

rejected. Powell asserted negligence, nuisance, and trespass against AAO. Powell alleged

inverse condemnation against the City for allowing AAO to act as it did to the detriment

and devaluation of the Powell property. Powell sought an injunction against both AAO and

the City from further construction activities.

In November 2020, Powell nonsuited the causes of action filed against AAO after it

asserted charitable immunity. In July 2021, Powell filed an amended complaint to add

AAO’s insurance company, The Cincinnati Indemnity Company, as a party to the lawsuit,

and added a claim of unjust enrichment against both the insurance company and the City.

Following discovery, the City moved for summary judgment in January 2023 asserting

that there was no evidence that the City intentionally accepted a defective stormwater

drainage design from AAO; there was no evidence that Powell’s property was substantially

devalued; that Powell was incorrectly relying on AAO’s initially rejected drainage plan; that

2 the City had approved a revised drainage plan in July 2019 that was compliant with city

requirements; and that the City was entitled to statutory immunity. The City attached the

affidavit of a city engineer, Powell’s responses to discovery, a copy of the 165-page revised

drainage plan that AAO presented to the City in July 2019, and an affidavit of the city

finance director.

Powell responded in resistance to the motion, providing an affidavit that said the

sports-complex construction artificially elevated the AAO seven to eight feet higher than the

adjoining Powell property; almost all vegetation was removed from the AAO property; the

City did not ensure that proper corrective measures were taken; AAO’s drainage pipe was

effectively “a water cannon” pointed toward the Powell property; Powell repeatedly expressed

concerns to both AAO and the City; and, regardless of Powell’s concerns, the Powell

property was routinely flooded by AAO’s drainage system. Powell contended that the City

had a duty, within its approval process with AAO, to prevent damage or adverse effects to

neighboring properties. Powell contended that the residence and shop had been penetrated

and damaged by the increased stormwater; that approximately three acres of the Powell

property regularly floods with stormwater; and that the stormwater effectively cut the Powell

property into two sections.

The City responded that it was entitled to summary judgment because Powell’s claim

of inverse condemnation was, in fact, a cause of action for negligence, from which the City

was statutorily immune pursuant to Ark. Code Ann. § 21-9-301. The City asserted that this

was not a city-constructed project, and none of the engineers or construction workers on the

3 AAO project were city employees or agents of the City. The City contended that Powell had

failed to prove any intentional harm and also failed to prove damages because Powell

presented an untimely affidavit in the response to the motion for summary judgment.

In March 2023, the circuit court entered a one-paragraph order denying the City’s

motion for summary judgment. This appeal followed. The only issue over which we have

jurisdiction in this interlocutory appeal is whether the circuit court erred in denying

summary judgment on the issue of immunity. City of Sherwood v. Bearden, 2023 Ark. App.

67, 661 S.W.3d 213.

Our law is well settled that summary judgment is to be granted by a circuit court only

when it is clear that there are no genuine issues of material fact to be litigated, and the

moving party is entitled to judgment as a matter of law. City of Sherwood, supra. Once the

moving party has established a prima facie entitlement to summary judgment, the opposing

party must meet proof with proof and demonstrate the existence of a material issue of fact.

Id. On appellate review, we determine if summary judgment was appropriate by deciding

whether the evidentiary items presented by the moving party in support of the motion leave

a material fact unanswered. Id. We view the evidence in the light most favorable to the party

against whom the motion was filed, resolving all doubts and inferences against the moving

party. Id. Our review focuses not only on the pleadings, but also on the affidavits and other

documents filed by the parties. Id.

4 The City contends that, rather than stating a claim for inverse condemnation, the

plaintiffs have alleged a tort claim from which the City is immune. Arkansas Code

Annotated section 21-9-301(a) (Supp. 2021) provides that

[i]t is declared to be the public policy of the State of Arkansas that all counties, municipal corporations, school districts, public charter schools, special improvement districts, and all other political subdivisions of the state and any of their boards, commissions, agencies, authorities, or other governing bodies shall be immune from liability and from suit for damages except to the extent that they may be covered by liability insurance.

The issue of whether a party is immune from suit is purely a question of law and is reviewed

de novo. City of Sherwood, supra.

Inverse condemnation is a cause of action against a governmental defendant to

recover the value of property that has been taken in fact by a governmental entity, although

not through eminent-domain procedures. Robinson v. City of Ashdown, 301 Ark. 226, 783

S.W.2d 53 (1990). “Fault” has nothing to do with eminent domain, and it is not bare

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Related

Robinson v. City of Ashdown
783 S.W.2d 53 (Supreme Court of Arkansas, 1990)
City of McCrory, Arkansas v. Wilson
2022 Ark. App. 200 (Court of Appeals of Arkansas, 2022)
City of Sherwood v. Clint Bearden
2023 Ark. App. 67 (Court of Appeals of Arkansas, 2023)

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Bluebook (online)
2024 Ark. App. 415, 698 S.W.3d 390, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-rogers-v-powell-arkctapp-2024.