Brown v. Lee, 424 S.W.3d 817

Brown and wife were involved in a 2004 auto collision with Lee; State Farm initially defended, later substituted by UIM payment.
Safeco paid its policy limits ($50,000) into the court registry; State Farm sought distribution to preserve subrogation rights.
Jury awarded Brown damages of $58,614 but found 40% fault, reducing recovery to $32,168.40 against Lee.
Circuit court ordered $50,000 payment to constitute partial satisfaction of any judgment; payment allocated to State Farm for its subrogation.
Lee moved for offset/credit and for entry of satisfaction; Brown objected and appealed challenging the offset, satisfaction, and authority.
Court held Lee entitled to offset based on $50,000 payment and allowed filing of a satisfaction of judgment; issues on appeal preserved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by allowing satisfaction of judgment.	Brown argues $50,000 was UIM payment, not Lee’s judgment payment.	Lee contends $50,000 was payment to satisfy judgment and preserve subrogation rights.	No error; offset/satisfaction permitted.
Whether the court should have sustained Brown's objection to satisfaction.	Objection preserved; satisfaction improper since grounds were not raised previously.	Objection waived; matters decided at trial and on record support offset.	Objection not preserved; affirm offset/satisfaction.
Whether the satisfaction of judgment is void and should be set aside.	Satisfaction entered improperly; grounds not argued below.	N/A or unnecessary since jurisdiction and offset valid.	Not void; properly entered as to offset.
Whether the circuit court had authority to grant an offset.	Lee lacked authority to claim offset; UCATA not applicable; no authority cited.	Court properly found entitlement to offset based on State Farm payment.	Authority recognized; offset valid.
Whether Brown was entitled to court costs.	Prevailing party entitled to costs; offset proceedings affect costs.	Brown failed to raise costs below; not preserved for review.	Costs not awarded to Brown; not preserved.

Boellner v. Clinical Study Ctrs., LLC, 2011 Ark. 83 (Ark. 2011) (claims not preserved for review when raised for first time on appeal)
Francis v. Protective Life Ins. Co., 371 Ark. 285 (Ark. 2007) (clerical error may be corrected by nunc pro tunc order)
Luches v. Luches, 262 Ark. 770 (Ark. 1978) (clerical error doctrine; record correction permitted)
Rossi v. Rossi, 319 Ark. 373 (Ark. 1995) (nunc pro tunc authority to reflect earlier act)
Lord v. Mazzanti, 339 Ark. 25 (Ark. 1999) (clarifies use of nunc pro tunc in correcting court records)