Schultz v. Butterball, LLC, 2012 Ark. 163

Schultz challenges a wage-withholding order from a California arrears case against his employer Butterball, LLC.
Butterball began withholding $700/month starting April 30, 2010 to satisfy past-due child support for Schultz's son.
Schultz filed May 11, 2011 in Franklin County circuit court seeking to enjoin further withholdings and damages, attaching a prior Stanislaus County order dismissal without prejudice.
The circuit court dismissed Schultz's complaint under Rule 12(b)(6), holding no civil liability for complying with a valid out-of-state order and that UIFSA required compliance.
Schultz argued the UIFSA subchapter is unconstitutional and that Stanislaus County failed to follow registration procedures; Butterball argued employer immunity from civil liability for complying.
The appellate court treated the motion as summary judgment due to outside-pleadings arguments and affirmed dismissal with prejudice.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Schultz stated a viable claim for wrongful wage withholding	Schultz	Butterball	No; employer not liable when complying with a valid withholding order under UIFSA
Whether UIFSA subchapter is constitutional	Schultz	Butterball	Constitutional; due process and redress rights not violated
Whether res judicata or collateral estoppel barred the action	Schultz	Butterball	Not addressed on written ruling; issues not preserved for review
Whether the dismissal should have been without prejudice due to summary-judgment handling	Schultz	Butterball	Dismissal with prejudice appropriate; no reversible error

McCrory v. Johnson, 296 Ark. 231 (1988) (due-process concerns in attachment statutes)
Washington v. Thompson, 389 Ark. 417 (1999) (registration of foreign orders upheld without pre-hearing)
Boellner v. Clinical Study Centers, LLC, 2011 Ark. 83 (2011) (oral ruling not effective without written order; review restriction)