Helena Agri-Enterprises, LLC v. Ellington Enterprises, Inc.
6:24-cv-06018
| W.D. Ark. | Apr 9, 2025Background
- Plaintiff Helena Agri-Enterprises sued Ellington Enterprises, Jerome Farms, Kim Ellington, and Sharon Ellington for breach of contract on unpaid balances from two open credit accounts used to purchase agricultural products.
- Defendants admitted to owing certain amounts on both accounts but disputed additional sums sought by Plaintiff, particularly where unsigned delivery tickets were involved.
- The contracts (Credit Agreements) were entered in March 2022 by Kim and Sharon Ellington as general partners for both defendant entities.
- Plaintiff moved for summary judgment, seeking a ruling on both admitted and disputed sums owed; Defendants countered that Plaintiff lacked proof of delivery for the amounts in dispute due to absent signed delivery tickets.
- The Court found no dispute about the admitted sums, but concluded factual issues existed regarding the additional sums based on evidence of unsigned delivery tickets and uncertainty over whether products were received.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Defendants breached the Credit Agreements and owe the undisputed balances | Defendants admit the breach and the amounts due | Admit breach and these amounts | For Plaintiff: summary judgment granted on these sums |
| Whether Plaintiff is entitled to additional sums (beyond admitted amounts) | Delivery tickets/invoices prove delivery and debt owed | No signed delivery tickets; no proof of receipt of goods | For Defendant: summary judgment denied on these sums |
Key Cases Cited
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (outlines the standard for summary judgment—requires genuine factual dispute to avoid judgment as a matter of law)
- Krenik v. Cnty. of LeSueur, 47 F.3d 953 (8th Cir. 1995) (describes the burden of showing a lack of genuine issue for summary judgment)
- Thomas v. Corwin, 483 F.3d 516 (8th Cir. 2007) (unsupported allegations are insufficient to overcome summary judgment)
- Rabalaias v. Barnett, 284 Ark. 527 (Ark. 1985) (explains the elements of a breach of contract claim in Arkansas law)