Truman Arnold Companies v. Miller County Circuit Court

Summary

The Supreme Court of Arkansas granted Truman Arnold Companies' petition for a writ of prohibition. It held that the Arkansas Workers' Compensation Commission has exclusive original jurisdiction to determine factual questions concerning whether the Workers' Compensation Act applies to an employee's negligence claims involving alleged sexual assault, and that the circuit court therefore lacked jurisdiction to proceed.

Holdings

1. The Arkansas Workers' Compensation Commission has exclusive original jurisdiction to determine facts establishing whether the Workers' Compensation Act applies, unless the facts are so one-sided that the issue is a question of law, such as a true intentional tort.
2. The circuit court acted without jurisdiction by weighing the complaint's factual allegations and reserving the power to make additional factual determinations about whether the claims were covered by the Workers' Compensation Act.
3. Jones's claims for negligent hiring, supervision, and retention did not satisfy the intentional-tort exception to the Workers' Compensation Act's exclusive-remedy provision.

Questions Presented

1. Whether the Miller County Circuit Court lacked jurisdiction to determine, based on factual allegations and potential factual development, whether Jones's negligence claims fell within the Workers' Compensation Act.
2. Whether the Workers' Compensation Commission has exclusive original jurisdiction to determine factual issues establishing the applicability of the Workers' Compensation Act, including whether the alleged injuries arose out of employment and whether the Act's mental-injury provisions or crime-of-violence exception applied.
3. Whether Jones's negligent hiring, supervision, and retention claims fell within the intentional-tort exception to the Workers' Compensation Act's exclusive-remedy provision.

Disposition

writ_granted