Seaside Pools, Inc. v. Robert Lee Curtis, Jr., and Sheila Dawn Curtis

2025 Ark. App. 155
CourtCourt of Appeals of Arkansas
DecidedMarch 12, 2025
StatusPublished

This text of 2025 Ark. App. 155 (Seaside Pools, Inc. v. Robert Lee Curtis, Jr., and Sheila Dawn Curtis) 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
Seaside Pools, Inc. v. Robert Lee Curtis, Jr., and Sheila Dawn Curtis, 2025 Ark. App. 155 (Ark. Ct. App. 2025).

Opinion

Cite as 2025 Ark. App. 155 ARKANSAS COURT OF APPEALS DIVISION IV No. CV-23-817

SEASIDE POOLS, INC. Opinion Delivered March 12, 2025 APPELLANT APPEAL FROM THE BENTON COUNTY CIRCUIT COURT V. [NO. 04CV-22-2183]

ROBERT LEE CURTIS, JR., AND HONORABLE CHRISTINE SHEILA DAWN CURTIS HORWART, JUDGE APPELLEES DISMISSED

BART F. VIRDEN, Judge

Appellant Seaside Pools, Inc., appeals from the Benton County Circuit Court’s order

granting summary judgment to appellees Robert Lee Curtis, Jr., and Sheila Dawn Curtis.

Seaside raises three points on appeal: (1) it is not a “residential contractor” under Ark. Code

Ann. § 18-44-115(a)(4) (Supp. 2017); (2) Act 984 of 2021 should be applied retroactively;

and (3) Act 808 of 2017 violates article 2, section 13 of the Arkansas Constitution. Because

the order does not dismiss all of the claims against all of the defendants and does not contain

a certification of finality pursuant to Ark. R. Civ. P. 54(b), we dismiss for lack of jurisdiction.

Arkansas Rule of Appellate Procedure–Civil 2(a)(1) provides that an appeal may be

taken only from a final judgment or decree entered by the trial court. A final order is one

that dismisses the parties, discharges them from the action, or concludes their rights to the

subject matter in controversy. A Time for You, LLC v. Park H Props., LLC, 2019 Ark. App. 282. Whether an order is final for appeal purposes is a jurisdictional question that this court

will raise sua sponte. Id. When more than one claim for relief is presented in an action or

when multiple parties are involved, an order that adjudicates fewer than all the claims or the

rights and liabilities of fewer than all the parties is not a final, appealable order. Ark. R. Civ.

P. 54(b)(1). The purpose of Rule 54(b) is to avoid piecemeal litigation. Neal v. Vaughn, 2018

Ark. App. 548, 565 S.W.3d 103.

In December 2020, Seaside contracted with the Curtises to install a swimming pool

at their home in Siloam Springs. When the Curtises failed to finish paying for their pool

after its completion, Seaside filed a complaint in August 2022 to impress and foreclose a lien

against the Curtises’ property. Seaside also named as defendants Generations Bank and

Charles S. Collins, Commissioner of Revenue for the Arkansas Department of Finance and

Administration (DFA), alleging that those defendants may have junior and inferior interests

in the Curtises’ property.

The Curtises and Generations Bank—but not DFA—moved to dismiss the complaint

against them pursuant to Ark. R. Civ. P. 12(b)(6). The trial court granted the motions to

dismiss without prejudice but permitted Seaside to amend its complaint to allege “one or

more different causes of action.” At the hearing, the court told Seaside that “unless [it got]

real creative” with its amended complaint, Generations Bank was “probably out.”

Seaside filed an amended and restated complaint against only the Curtises for breach

of contract and sought a personal judgment, i.e., it omitted the lien-foreclosure action.

Seaside nevertheless served the amended complaint not only on the Curtises but also on

2 Generations Bank and DFA. Moreover, in paragraph 10 of the amended complaint, Seaside

alleged the following:

In that this Court has previously dismissed the original complaint against the Generations Bank and Charles Collins, Commissioner of Revenue for the Department of Finance and Administration of Arkansas, no new allegations are made against them in that they are no longer parties in this case. However, Plaintiff amends its complaint without prejudice to appealing this Court’s order dismissing such Defendants from this case.

(Emphasis added.)

The Curtises answered the amended complaint. DFA also filed an answer, denying

that it had been dismissed and stating that, pursuant to a certificate of indebtedness, it has

a statutory lien on the Curtises’ property that has the force and effect of a circuit court

judgment against all of a taxpayer’s personal and real property.

The Curtises then moved for summary judgment, which was granted. Specifically, the

trial court ruled that Seaside is a residential contractor required to give lien notice under the

version of section 18-44-115(a)(4) in effect when the parties entered the contract; that Seaside

failed to give notice and does not qualify under the direct-sale exemption; that section 18-

44-115(a)(4) does not violate article 2, sections 13 and 17 of the Arkansas Constitution; 1 and

1 Arkansas Code Annotated section 16-111-111(a) (Supp. 2023) provides that if a statute is alleged to be unconstitutional, the Attorney General shall also be served with a copy of the proceeding and be entitled to be heard. Here, at the end of its amended and restated complaint, below its certificate of service swearing that a copy of the complaint had been emailed to the attorneys for the Curtises, Generations Bank, and DFA, and below the signature line for Seaside’s attorney who swears to such service, Seaside included a single sentence stating the following:

3 that the 2021 amendment to section 18-44-115 does not apply retroactively. It is from this

order that Seaside appeals. In its notice of appeal, Seaside did not abandon any pending but

unresolved claims pursuant to Ark. R. App. P.–Civ. 3(e).2

Generally, the dismissal of a claim without prejudice does not create finality. Park

Plaza Mall CMBS, LLC v. Powell, 2018 Ark. App. 48; Ratzlaff v. Franz Foods of Ark., 255 Ark.

373, 500 S.W.2d 379 (1973). By contrast, the dismissal of a party to an action, with or

without prejudice, is sufficient to obtain finality and invest jurisdiction in an appellate court.

See, e.g., Driggers v. Locke, 323 Ark. 63, 913 S.W.2d 269 (1996).

Although Seaside purports to have “dropp[ed] all of the other defendants” when it

amended its complaint to omit any claim to a lien, DFA and the claims against it have not

In accordance with ARCP 24 and A.C.A. § 16-111-111, Plaintiff is notifying the Attorney General of the State of Arkansas, Tim Griffin, that a constitutional challenge has been made to the aforementioned statute.

We note that, although Seaside suggests it has notified—or will notify—the Attorney General, Seaside’s attorney has not similarly sworn that the Attorney General was served with a copy of the amended complaint. In fact, there is no indication in the record that there has been any communication between Seaside and the Attorney General. Although it is not a jurisdictional requirement, City of Little Rock v. Cash, 277 Ark. 494, 644 S.W.2d 229 (1982), we encourage Seaside to ensure that it has complied with the notice statute. See, e.g., Olmstead v. Logan, 298 Ark. 421, 768 S.W.2d 26 (1989) (holding that the failure to provide Attorney General with notice of constitutional challenge was reversible error); see also Reagan v. City of Piggott, 305 Ark. 77, 805 S.W.2d 636 (1991) (refusing to consider constitutional challenge because record did not reveal that Attorney General had been notified or that issues were adequately argued or briefed by truly adversarial parties).

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