Geraldine Henson, as Personal Representative of the Estate of David Henson v. Kelley Cradduck, 593 S.W.3d 10

Sept. 29, 2012: David Henson arrested and confined at Benton County Detention Facility; placed in detox and hospitalized Oct. 5 and died the next day from alcohol withdrawal/chronic alcoholism.
Geraldine Henson was appointed administratrix Aug. 14, 2014, and filed a pro se wrongful-death complaint on Oct. 5, 2015 (within three-year limitations period measured from death).
Appellant later retained counsel and filed multiple amended complaints; first attorney-filed complaint was Nov. 16, 2015 (after the three-year limitations date).
Defendants moved to dismiss, arguing the pro se complaint by a nonlawyer personal representative was the unauthorized practice of law and therefore a nullity, so later pleadings could not relate back and were time‑barred.
The circuit court dismissed all claims as time‑barred; this Court affirmed, holding the pro se complaint was a nullity under precedent and that the attorney-filed complaints were untimely. A dissent argued the original pleading was not a nullity because Henson was the sole heir and amendments should relate back.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the law‑of‑the‑case doctrine bars reconsideration of jurisdiction	Henson: prior appellate decision precludes re‑litigation of jurisdiction	Defendants: prior decision only resolved appellate‑jurisdiction threshold	Court: Doctrine did not bar review — prior opinion only addressed appellate jurisdiction
Whether a nonlawyer personal representative’s pro se wrongful‑death complaint constitutes unauthorized practice of law (nullity)	Henson: her pro se complaint was timely and valid; she acted as sole heir/representative	Defendants: nonlawyer PR cannot litigate for beneficiaries; pro se complaint is nullity under precedent	Court: Pro se complaint was unauthorized practice and thus a nullity
Whether later attorney‑filed amended complaints relate back to the original pro se filing for limitations purposes	Henson: amended complaints arise from same transaction and thus relate back	Defendants: a null original pleading cannot serve as a basis to relate back	Court: Amendments could not relate back to a nullity; attorney pleadings were filed after limitations expired
Whether other merits (sufficiency of claims, John Doe defendants, immunity) should be decided	Henson: claims stated; defendants not immune	Defendants: claims meritless or barred/immunities apply	Court: Merits not reached — dismissal on statute‑of‑limitations grounds was dispositive and dispositive

Henson v. Cradduck, 2017 Ark. 317, 530 S.W.3d 847 (Ark. 2017) (prior appellate decision addressing appellate‑jurisdiction posture)
Davenport v. Lee, 348 Ark. 148, 72 S.W.3d 85 (Ark. 2002) (holding nonlawyer personal representative’s pro se wrongful‑death complaint is unauthorized practice of law and a nullity)
DeSoto Gathering Co. LLC v. Hill, 2017 Ark. 326, 531 S.W.3d 396 (Ark. 2017) (standard of review for unauthorized‑practice questions; Supreme Court’s authority to regulate practice of law)
Ark. Bar Ass’n v. Union Nat’l Bank, 224 Ark. 48, 273 S.W.2d 408 (Ark. 1954) (bank acting as personal representative engaged in unauthorized practice of law)
Brewer v. Lacefield, 301 Ark. 358, 784 S.W.2d 156 (Ark. 1990) (personal representative is trustee of conduit in wrongful‑death actions)
Worden v. Kirchner, 2013 Ark. 509, 431 S.W.3d 243 (Ark. 2013) (motion‑to‑dismiss standards)
Dockery v. Morgan, 2011 Ark. 94, 380 S.W.3d 377 (Ark. 2011) (abuse‑of‑discretion standard for dismissal)