Mountain Home Flight Service, Inc. v. Baxter County, 758 F.3d 1038

MHFS leased space at Baxter County Airport in 1992 to operate MHFS hangar and provide flight services under a lease requiring compliance with Commission Minimum Standards.
Minimum Standards were formalized in 1993 and allegedly governed MHFS actions and required airport-manager approval for certain moves.
Doyle Linck and Hugh McClain previously operated a competing hangar and fuel service; MHFS later acquired Linck’s hangar and operated both as a single operation.
Throughout 2005–2007, county and Commission efforts to recruit other operators and to construct a competing county hangar escalated, affecting MHFS’s business options.
In 2012 MHFS filed federal suit asserting breach of contract, tortious interference, and § 1983 due process claims, among others; district court dismissed all claims and declined supplemental jurisdiction over two remaining state-law claims.
MHFS appeals the district court’s dismissal and post-dismissal motions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the contract claim survives state-law standards	MHFS asserts breach via bad-faith performance.	County/Commission argue no separate cause of action for bad-faith duty.	Claim rejected; no independent breach of contract recognized.
Whether tort claims were time-barred or inadequately pleaded	MHFS pled timely, viable interference claims.	Many acts outside 3-year limit; no improper interference pleaded.	Tort claims dismissed for lack of timely, improper interference.
Whether § 1983 and § 16-123-105 claims were time-barred	Claims should be timely under federal/Arkansas analogs.	Three-year statute applies; most facts outside period.	Claims dismissed as time-barred; statute of limitations applied.
Whether the district court properly declined supplemental jurisdiction over state-law claims	State-law claims should proceed with federal claims.	After § 1983 claims dismissed, no original jurisdiction remains.	District court acted within discretion to decline supplemental jurisdiction.
Whether the post-dismissal motion to amend was properly denied	Amendment should be permitted after dismissal.	Dismissal indicated final action; amendment inappropriate.	No abuse of discretion; action considered final and unamendable.

Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard)
Twombly v. Bell Atlantic Corp., 550 U.S. 544 (U.S. 2007) (facially plausible claim required)
Smith v. Boyd, 945 F.2d 1041 (8th Cir. 1991) (pre-dismissal notice not required for de novo review)
Quality Optical of Jonesboro, Inc. v. Trusty Optical, LLC, 225 S.W.3d 369 (Ark. 2006) (three-year limitations for tort claims; no continuing-tort theory)
Stewart Title Guar. Co. v. Am. Abstract & Title Co., 215 S.W.3d 596 (Ark. 2005) (elements of tortious interference; improper interference factors)
Wilson v. Garcia, 471 U.S. 261 (U.S. 1985) (statutes of limitations borrowing from state law for § 1983 actions)
Med. Liab. Mut. Ins. Co. v. Alan Curtis LLC, 519 F.3d 466 (8th Cir. 2008) (predicting Arkansas would apply 3-year limitations to similar rights actions)
Hannon v. Sanner, 441 F.3d 635 (8th Cir. 2006) (§ 1983 framework and limitations guidance)
Geier v. Missouri Ethics Comm’n, 715 F.3d 674 (8th Cir. 2013) (analysis of dismissal and amendment post-dismissal)