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305 Ark. 68

Brantley v. Davis

Supreme Court of Arkansas

Decided March 18, 1991

Supreme Court of Arkansas · decided 1991-03-18

Cited by 10 later decisions — most recently April 2005

10 state decisions

Key passage — most relied on by later courts

“(a) For good cause and at any time within the period allowed for appeal after the final termination of the administration of the estate of a decedent or ward, the court may vacate or modify an order or grant a rehearing. However, no such power shall exist as to any order from which an appeal has been taken or to set aside the probate of a will after the time allowed for contest thereof. (b) No vacation or modification under this section shall affect any act previously done or any right previously acquired in reliance on such order or judgment.”

quoted by 1 later decision, including Helena Regional Medical Center v. Wilson

Applies AR 28 § 28-1-115

Relies on Screeton v. Crumpler

Good law ✅— No negative treatment on recordhow we know

Decided 1991-03-18

View the full empirical analysis of this case →

David Newbern, Justice,

¶1concurring. While I agree with the result reached by the Court’s opinion, I do not believe it should have relied on Screeton v. Crumpler, 273 Ark. 167, 617 S.W.2d 847 (1981). As the Court’s opinion states, the Screeton opinion does not mention the applicable statute, Ark. Code Ann. § 28-1-115 (1987). Apparently the statute, which was in effect at the time was not cited to the Court which was unaware of it. Had the statute been at issue in that appeal it probably would have been decided differently.

¶2Subsection (b) of the statute, not cited in the majority opinion, is as follows: “No vacation or modification under this section shall affect any act previously done or any right previously acquired in reliance on such order or judgment.” The General Assembly was apparently aware of the disruption which could be caused by reopening but chose to provide for it with some protection of persons whose rights might be affected.

¶3The question here should be limited to whether the probate judge abused his discretion in finding no good cause to allow refiling of the will contest. In my view, there was no abuse.

Holt, C.J., joins in this concurrence.
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