Entergy Arkansas, Inc. v. Pope County Circuit Court
2014 Ark. 506
| Ark. | 2014Background
- In March 2013 a crane collapse at Arkansas Nuclear One killed journeyman iron worker Wade Walters (a PSC employee) and injured others during a stator replacement project.
- Walters’s administratrix, Susan Allen, sued Entergy Arkansas, Entergy Operations (operator/agent of owner), DP Engineering, PSC, and others in Pope County Circuit Court alleging wrongful death and multiple negligence theories; no claim was filed first with the Workers’ Compensation Commission.
- Entergy and DP moved to dismiss (or stay) asserting immunity under the Arkansas Workers’ Compensation Act — claiming Walters was a statutory or special employee of Entergy (and that DP’s employee was a special co‑employee entitled to co‑employee immunity).
- The circuit court denied the motions, finding PSC (not Entergy or DP) was the employer and that the facts did not establish statutory/special employer status as a matter of law; it also said sending DP’s claims to the Commission would violate the right to jury trial.
- Entergy and DP petitioned this court for writs of prohibition, arguing the Commission has exclusive, original jurisdiction to decide employer status and immunity under the Act.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the circuit court had jurisdiction to decide if Act immunities (statutory/special employer; co‑employee immunity) apply | Allen: circuit court properly decided the motions because facts were one‑sided and immunity could be resolved as a matter of law | Entergy/DP: the Commission has exclusive, original jurisdiction to determine employer status and applicability of the Act; circuit court was wholly without jurisdiction | Court: grant prohibition — Commission has exclusive original jurisdiction unless facts are so one‑sided they become a question of law; here facts were not one‑sided, so circuit court lacked jurisdiction |
Key Cases Cited
- Gourley v. Crossett Pub. Schs., 333 Ark. 178 (1998) (explains exclusivity doctrine of workers’ compensation immunity)
- Van‑Wagoner v. Beverly Enterprises, 334 Ark. 12 (1998) (Commission has exclusive original jurisdiction unless facts are so one‑sided they present a legal question)
- Int'l Paper Co. v. Clark Cnty. Cir. Ct., 375 Ark. 127 (2009) (reiterating Commission’s primary role in determining employer status)
- Carter v. Ga.‑Pac. Resins, Inc., 368 Ark. 19 (2006) (emphasizing Commission expertise and goals of uniformity, speed, simplicity)
- Reynolds Metal Co. v. Circuit Court of Clark County, 428 S.W.3d 506 (Ark. 2013) (same rule: Commission has exclusive, original jurisdiction over factual determinations of employer status)