Here’s an analysis of the case University Medical Pharmaceuticals Corp. v. Team Direct Management, LLC, decided by the Arkansas Court of Appeals on May 14, 2025. You can read the text of the opinion by clicking here.

Case Overview

  • Appellant: University Medical Pharmaceuticals Corp.
  • Appellee: Team Direct Management, LLC
  • Court: Arkansas Court of Appeals
  • Citation: 2025 Ark. App. 297
  • Appeal From: Benton County Circuit Court
  • Judge: Hon. Christine Horwart

Core Facts

  • Team Direct sued University Medical in 2021 with three claims: 

    1. Breach of written contract 
    2. Promissory estoppel 
    3. Unjust enrichment

  • Before trial, Team Direct voluntarily dismissed the breach of contract claim (without prejudice).

  • At a bench trial, the court ruled in Team Direct’s favor for unjust enrichment and awarded $460,837.02.

  • University Medical appealed this judgment.

Was there a “final order” that could be appealed?

  • Arkansas law requires that an order must resolve all claims and parties (or have a special certification) to be considered final for appeal.
  • Here, the breach of contract claim was dismissed without prejudice, so it could be refiled. The promissory estoppel claim was not addressed in the court’s final order.

Court’s Ruling

  • The Court of Appeals dismissed the appeal without prejudice. 
  • They held that, because not all claims were resolved (promissory estoppel was left open and breach of contract could be refiled), the order was not truly “final.”
  • No Rule 54(b) certificate was issued to make the partial judgment appealable.
  • The appellate court, therefore, did not have jurisdiction to hear the appeal.

Key Takeaways and Implications

  • Finality is crucial: Parties can’t appeal unless every claim is resolved or the court certifies the order as final under Rule 54(b).
  • Voluntary nonsuit (dismissal without prejudice) does not create finality: The ability to refile means the claim is not truly over.
  • Unresolved claims block appeals: If any claim (like promissory estoppel here) is unaddressed, there’s no appealable order.
  • Practical effect: The trial court’s judgment stands, but a proper final order must be entered (addressing all claims or dismissing them with prejudice, or with a Rule 54(b) certificate) before an appeal can proceed.

Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve brain damage, heart damage, spinal cord injuries or severe burns in Texas, Arkansas and Oklahoma. Contact us at www.girardslaw.com by using the chat feature for more information.

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