Reasor-Hill Corporation v. Harrison

Supreme Court of Arkansas · 1952 · Civil Procedure

249 S.W.2d 994 (1952)

Updated July 29, 2026

Civil ProcedureJurisdictionLocal and transitory actionsInjury to out-of-state real propertyprohibitioncross-complaintout-of-state landreal property

Facts

Planters Flying Service sued Barton in Arkansas to collect an account for spraying insecticide on Barton's cotton crop in Missouri. In response, Barton alleged that the flying service damaged his growing crop by using an adulterated insecticide and filed a cross-complaint against Reasor-Hill, an Arkansas corporation that manufactured the chemical, claiming it negligently put on the market an insecticide unsuited to spraying cotton. Reasor-Hill was not authorized to do business in Missouri. Reasor-Hill argued that Arkansas courts lacked jurisdiction because the cross-complaint sought damages for injury to real property located in Missouri.

Issue

May Arkansas courts entertain a suit for injuries to real property situated in another state? More specifically, may an Arkansas court hear Barton's cross-complaint against an Arkansas corporation for damage to a growing cotton crop in Missouri?

Rule

Arkansas courts may entertain an action for injuries to real property situated in another state. The court rejects the traditional common-law rule denying jurisdiction over such claims when applied to interstate disputes within the United States.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Alvarez owns a peach orchard in Tennessee. She sues Delta Crest Agri-Chem, an Arkansas corporation based in Jonesboro, in Arkansas state court, alleging that a defective fungicide manufactured in Arkansas damaged the growing peaches on her Tennessee land.

Delta Crest moves to dismiss, arguing that the claim is a local action that can be heard only where the land is located. How should the Arkansas court rule?

Explanation. The majority rule in this case is that Arkansas courts may entertain suits for injuries to real property located in another state. The court rejected the traditional local-action bar for interstate disputes within the United States, reasoning that the old English rule lacks sufficient logic or equity in this context and should not leave a wrong without a remedy.