Jesse Cureton and Joie Cureton v. Calvin Stout Cv-18-651

2020 Ark. App. 414
CourtCourt of Appeals of Arkansas
DecidedSeptember 16, 2020
StatusPublished
Cited by2 cases

This text of 2020 Ark. App. 414 (Jesse Cureton and Joie Cureton v. Calvin Stout Cv-18-651) 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
Jesse Cureton and Joie Cureton v. Calvin Stout Cv-18-651, 2020 Ark. App. 414 (Ark. Ct. App. 2020).

Opinion

Reason: I attest to the accuracy and integrity of this document Date: Cite as 2020 Ark. App. 414 2021-07-08 15: 06:09 ARKANSAS COURT OF APPEALS Foxit DIVISION I PhantomPDF Version: 9.7.5 No. CV-18-651

JESSE CURETON AND JOIE Opinion Delivered: September 16, 2020 CURETON APPELLANTS APPEAL FROM THE WASHINGTON V. COUNTY CIRCUIT COURT [NO. 72CV-17-470] CALVIN STOUT APPELLEE HONORABLE DOUG MARTIN, JUDGE

APPEAL DISMISSED

MIKE L. MURPHY, Judge

This appeal is a companion to Cureton v. Stout, 2020 Ark. App. 406, also handed

down today.1 In this appeal, Jesse Cureton and Joie Cureton appeal the compensatory-

damages award received from a jury trial in the Washington County Circuit Court. 2 For

the reasons explained below, we must dismiss the appeal for lack of a final, appealable order.

Siblings Jesse Cureton and Joie Cureton were injured in a multivehicle accident on

September 25, 2016. The accident occurred when the appellee Calvin Stout attempted a

left-hand turn in front of on-coming traffic, and his vehicle collided with a vehicle driven

1 Both appeals arise out of a single lawsuit wherein appellants sought both compensatory and punitive damage from appellee Calvin Stout as a result of a motor-vehicle accident. 2 Although judgment was entered against Stout, he has not appealed. by Edward Stith.3 This initial collision forced Stith’s vehicle into the Cureton vehicle. Stout

was subsequently charged with driving while intoxicated and later pled guilty.

On March 9, 2017, the Curetons4 filed suit against Stout, alleging negligence and

seeking both compensatory and punitive damages because Stout was driving while

intoxicated at the time of the motor vehicle collision. Stout answered the complaint,

admitting liability for all compensatory damages to the Curetons but denying that he was

liable for punitive damages.

Stout moved to bifurcate the proceedings into two stages, compensatory damages

and punitive damages, pursuant to Arkansas Rule of Civil Procedure 42(b). He argued that

because he had admitted liability, the only relevant issues at the compensatory-damages stage

were the injuries and the amount of compensatory damages sustained by the plaintiffs as a

result of the accident. He contended that evidence of his intoxication or that some conduct

may have been willful, wanton, or intentional, on the other hand, was relevant only with

respect to the claim for punitive damages.

3 Stith was not named as a party in the subsequently filed lawsuit. 4 The plaintiffs in the initial complaint were Jesse, who was the driver of the vehicle, and Chad and Monica Cureton, in their capacity as parents and guardians of Joie, who was a passenger and a minor at the time of the accident. During the pendency of the case, Joie reached the age of majority. The complaint was amended numerous times thereafter, but in the final amended complaint filed, Chad and Monica were still listed as parties although the complaint alleged that they were no longer necessary parties due to Joie’s reaching the age of majority. The appellate record indicates the court orally dismissed Chad and Monica on the morning of trial; however, we were unable to find in our record any order either substituting Joie for Chad and Monica or any order formally dismissing Chad and Monica as parties. We note an oral ruling is not sufficient to dismiss a party from an action, as an oral order announced from the bench does not become effective until reduced to writing and filed. Ark. Sup. Ct. Admin. Order No. 2(b)(2) (2019); McGhee v. Ark. Bd. of Collection Agencies, 368 Ark. 60, 243 S.W.3d 278 (2006).

2 The Curetons opposed the motion to bifurcate, arguing that it should be denied

because it would violate judicial economy and prejudice their claims. Additionally, they

argued that Stout failed to show that bifurcation was needed.

On March 7, 2018, the circuit court entered an order granting Stout’s motion to

bifurcate. The court found that, given Stout’s admission of liability, evidence concerning

intoxication had only limited probative value to the issue of compensatory damages. The

court also found that pursuant to Arkansas Rule of Evidence 403, the risk of undue prejudice

of such evidence during the compensatory phase of the trial substantially outweighed any

probative value it may have under Arkansas Rule of Evidence 401. The circuit court

bifurcated the compensatory- and punitive-damages claims pursuant to Rule 42(b) of the

Arkansas Rules of Civil Procedure into separate phases of one trial to be conducted before

the same jury.

On March 8, 2018, Stout filed a second motion in limine. In this motion, he sought

to exclude any history of prior DUIs or DWIs he had received as completely irrelevant to

any phase of trial or any issue remaining to be tried. He had testified in a deposition that he

had received more than one DWI or DUI over thirty years prior to the accident in this case.

In their March 9, 2018 response to Stout’s motion in limine, the Curetons agreed

that because Stout admitted liability, the traffic citations and subsequent convictions were

not relevant in the compensatory-damages phase of the trial. The Curetons stated that they

understood the court’s ruling on the motion to bifurcate and would abide by the ruling.

The parties proceeded to a jury trial on March 13-14, 2018. After completing the

compensatory-damages phase of the trial, the jury returned with separate verdicts awarding

3 the Curetons $1,000 each in compensatory damages. Each verdict form was signed by ten

jurors. The parties then commenced the second punitive-damages phase of the trial.

During his opening statement of the punitive-damages phase, the Curetons’ attorney

said “we’re asking you to punish the defendant for his behavior. This was not his first DWI.”

Stout’s attorney immediately asked to approach the bench, at which time he objected and

brought up his second motion in limine about the prior DWIs and the court’s handling of

the matter in chambers prior to trial. The court agreed that its orders and/or instructions

had been violated by the Curetons’ attorney and that there was no way to cure such a

violation. Stout sought a mistrial only as to the punitive-damages phase because the

compensatory-damages phase had been tried and the jury had rendered verdicts and also

because the punitive-damages phase could be heard separate and apart from the

compensatory-damages trial. The Curetons argued that any mistrial should be for both

phases of the case. The court granted the mistrial only as to the punitive-damages phase and

discharged the jury.5 The court’s mistrial ruling was memorialized in a detailed order entered

on March 22, 2018.

On April 10, 2018, judgment was entered on the jury’s verdicts of compensatory

damages. On May 10, the Curetons filed their notice of appeal from this judgment.

The Curetons raise several points in this appeal. We are not able to address the merits

of the appeal at this time due to finality issues. Whether an order is final and subject to

appeal is a jurisdictional question that this court will raise sua sponte. Moses v. Hanna’s Candle

5 On July 11, 2018, a separate jury heard the evidence on punitive damages and rendered a verdict that is the basis of the companion appeal. See Cureton v. Stout, 2020 Ark. App. 406, the companion case handed down this day.

4 Co., 353 Ark.

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