Matthew Fraser v. Carroll Electric Cooperative Corp.

2026 Ark. App. 138
CourtCourt of Appeals of Arkansas
DecidedFebruary 25, 2026
StatusPublished

This text of 2026 Ark. App. 138 (Matthew Fraser v. Carroll Electric Cooperative Corp.) 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
Matthew Fraser v. Carroll Electric Cooperative Corp., 2026 Ark. App. 138 (Ark. Ct. App. 2026).

Opinion

Cite as 2026 Ark. App. 138 ARKANSAS COURT OF APPEALS DIVISIONS III & IV No. CV-24-572

MATTHEW FRASER Opinion Delivered February 25, 2026 APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CV-23-3081]

CARROLL ELECTRIC COOPERATIVE HONORABLE JOHN R. SCOTT, CORPORATION JUDGE APPELLEE

AFFIRMED IN PART; REVERSED AND REMANDED IN PART

WAYMOND M. BROWN, Judge

Appellant Matthew Fraser appeals the order of the Benton County Circuit

Court dismissing his claim for a private nuisance against appellee Carroll Electric

Cooperative Corporation (CECC) upon finding that the Arkansas Public Service

Commission (PSC) has jurisdiction to hear the claim. The circuit court had previously

granted CECC’s motion to dismiss appellant’s claim for trespass. Appellant argues on appeal

that the circuit court erred by (1) finding that the existence of an easement in favor of CECC

across a portion of appellant’s property automatically foreclosed a claim of trespass without

considering whether the conduct complained of fell within the terms of the easement or

constituted an abuse of CECC’s easement; (2) finding that a PSC order establishing the

tariffs for street-lighting service provided by CECC preempts appellant’s common-law rights to seek redress for the maintenance of a private nuisance created and maintained by CECC

on appellant’s property; and (3) making dispositive rulings based on matters first raised

during oral argument and without requiring CECC to put the motion in writing and without

allowing appellant ten days to respond. We affirm in part and reverse and remand in part.

Appellant filed a complaint against CECC and Curtis Mincer and Denise Reed

(neighbors) on November 7, 2023. The complaint alleged that a security light containing an

LED fixture installed and maintained by CECC at the request of the neighbors near the

corner of appellant’s property line with the neighbors constituted a trespass and nuisance on

his property because the bright light was offensive and interfered with appellant’s use and

enjoyment of his home and property.1 According to the complaint, the offensive light shines

directly into appellant’s daughter’s bedroom, interfering with her sleep and detracting from

the comfortability of the room at night. Appellant noted that the light had been re-aimed,

but he complained that while this reduced the direct light on his house, it caused the light

from the LED to be brighter on the corner of appellant’s property. Appellant alleged that it

sought help from the Arkansas Natural Sky Association (ANSA), an environmental group

that tries to help people with light-trespass problems. ANSA investigated appellant’s

situation and subsequently drafted a report stating that the lighting was excessive and

constituted a private nuisance on appellant’s property. It also suggested a proper way to

1 Appellant’s home is one of eighty-seven homes in the neighborhood. The home was purchased by appellant in September 2022, and the LED lighting existed at least three years before appellant’s purchase.

2 address security concerns with lighting. CECC’s attorney was provided with a copy of the

report. Appellant sought injunctive relief, compensatory damages, and exemplary damages,

jointly and severally, from the defendants.

CECC filed its answer to the complaint and a motion to dismiss appellant’s

complaint along with an accompanying brief pursuant to Ark. R. Civ. P. 12(b)(6) based on

appellant’s failure to state facts upon which relief could be granted on December 6, 2023.

CECC also filed a counterclaim for prescriptive easement. Attached as exhibits to the

counterclaim were a copy of its tariff regarding security lighting on file with the PSC and a

copy of the easement granted to it by Cooper Communities, the developer of Bella Vista,

the community in which appellant’s house is located. CECC claimed in its motion to

dismiss that appellant had failed to sufficiently allege causes of action for both the trespass

and nuisance claims. Appellant responded to the motion to dismiss, disagreeing that he had

failed to state facts upon which relief could be granted and discussing the law on trespass

and nuisance.

Appellant filed an amended complaint on December 8, 2023. CECC filed its answer

to the amended complaint and renewed its motion to dismiss on December 13. Appellant

filed his second amended complaint on January 2, 2024, again alleging a trespass and

nuisance claim against CECC relating to the light located on the easement on appellant’s

property. Appellant claimed the following damages: “injury to the use and enjoyment of his

property”; that the “injury has been, and is, actual”; that said injury “is certain, substantial,

and beyond speculation and conjecture”; and that the light “makes [appellant’s] use and

3 enjoyment of his property much more difficult,” “makes [appellant’s] use and enjoyment of

his property abusive to senses,” and “includes increased health risks.” Appellant sought

injunctive relief and compensatory and exemplary damages. CECC filed its answer and its

counterclaim for prescriptive easement; it also renewed its motion to dismiss.

A hearing took place on February 2, 2024. At that hearing, appellant stated that he

had never claimed the light was the trespass but that the trespass was the box that controls

the light and the lightbulb that was on appellant’s property. He also stipulated at the hearing

that CECC’s light fixture and box were on its easement. CECC received a partial order of

dismissal for the trespass claim, which was filed on February 12. The neighbors also obtained

an order dismissing the complaint for both the trespass and nuisance claims against them,

and the order was filed on February 15.

Appellant filed a motion and brief for permanent injunction on March 29 asking the

circuit court to issue a permanent injunction requiring CECC to remove the light. CECC

filed a response alleging that the circuit court was without jurisdiction to consider the

complaint for injunctive relief and that appellant’s motion was untimely since the case had

not been tried on its merits. CECC stated that it had established a device around the light

fixture that shielded appellant’s property from most of the light emitted and focused the

light away from appellant’s property. CECC filed a motion to dismiss for lack of subject

matter jurisdiction and accompanying brief on April 15 asking the circuit court to find that

the PSC had primary and exclusive jurisdiction to hear the case. Appellant responded that

(1) circuit courts are courts of general jurisdiction, (2) Ark. Code Ann. §§ 23-18-308 and 23-

4 2-304 did not provide jurisdiction to the PSC, (3) Ark. Code Ann. § 23-3-119 did not grant

the PSC jurisdiction to hear common-law claims, (4) every case cited by CECC involved rates

charged, and (5) CECC failed to cite the only controlling case on point, which he alleged

was Stanley v. Ozarks Electric Cooperative Corp..2

Appellant filed a motion and brief for bench trial on injunction and jury trial on

damages on May 14. CECC filed a reply to appellant’s response to its motion to dismiss on

May 20, citing Capps v. Carroll Electric Cooperative Corp.,3 and contending that because it did

not address rates charged but rather alleged a tort, the case was still subject to PSC

jurisdiction and not circuit court jurisdiction.

CECC’s motion to dismiss was heard on May 20.

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2026 Ark. App. 138, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matthew-fraser-v-carroll-electric-cooperative-corp-arkctapp-2026.