Joe Terry and David Lee Stocks v. A.D. Lock, Lock Hospitality, Inc., Greg Entler, John Doe I, John Doe II, and John Doe III

Summary

The Supreme Court of Arkansas held that a chancery court had jurisdiction under the clean-up doctrine to resolve claims concerning ownership of money discovered during motel renovations. The court affirmed the finding that the money was mislaid property, giving the premises owner superior possessory rights over the finders, subject to the rights of the true owner.

Holdings

1. The chancery court had subject-matter jurisdiction because the complaint sought equitable remedies, including an injunction, specific performance, and a constructive trust; once equity jurisdiction was properly invoked, the court could resolve the remaining related claims under the clean-up doctrine.
2. The chancery court did not clearly err in finding that the currency was intentionally placed in the motel ceiling and later forgotten, making it mislaid property. As against the finders, Lock Hospitality, Inc., as owner of the premises, had the superior right to possession.

Questions Presented

1. Whether the chancery court had subject-matter jurisdiction under Arkansas's clean-up doctrine to adjudicate ownership of the currency and related tort claims.
2. Whether the chancery court clearly erred by classifying the concealed currency as mislaid property rather than lost, abandoned, or treasure-trove property.
3. Whether Lock Hospitality, Inc., as owner of the premises, had the superior right to possession of the mislaid property against the finders.

Disposition

affirmed