The Logan Ctrs. Inc v. Walker, 2014 Ark. App. 203

Carla Walker (administratrix for Antonio Cozart) filed a medical-malpractice/wrongful-death complaint against The Logan Centers, Inc., et al.
Defense counsel filed a notice of appearance and, before the answer deadline, filed a motion for an extension of time to respond under Ark. R. Civ. P. 6(b)(1).
Plaintiff moved to object to any extension and sought default judgment; defense filed its answer seven days after the answer deadline.
The trial court denied the pre-deadline extension motion, struck the untimely answer, and entered default judgment for plaintiff.
Appellants appealed the order striking the answer; this Court has immediate jurisdiction under Ark. R. App. P.–Civ. 2(a)(4).
The central legal question was whether the trial court applied the correct Rule 6(b) standard: the less stringent pre-expiration "for cause shown" standard (subsection (1)) or the post-expiration "mistake/ excusable neglect" standard (subsection (2)).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court should have applied Rule 6(b)(1) (pre-expiration "for cause shown") or Rule 6(b)(2) (post-expiration "mistake/inexcusable neglect") to deny the requested extension	The trial court correctly denied relief because an extension should be denied absent the stronger showing (invoking Layman)	An extension request made before the deadline is governed by Rule 6(b)(1)’s "for cause" standard, which is less stringent and typically granted absent bad faith or prejudice	The Court held the Rule 6(b)(1) standard applies to motions filed before the deadline; the trial court erred by applying the subsection (2) standard. Reversed and remanded.

Layman v. Bone, 333 Ark. 121 (1998) (discusses application of Rule 6(b) and standards for post-deadline extensions)