Arkansas Code Annotated

Ark. Code Ann. § 16-108-228 (2026)

Appeals

✓ current as of May 2026
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  1. An appeal may be taken from:
    1. an order denying a motion to compel arbitration;
    2. an order granting a motion to stay arbitration;
    3. an order confirming or denying confirmation of an award;
    4. an order modifying or correcting an award;
    5. an order vacating an award without directing a rehearing; or
    6. a final judgment entered under this subchapter.
  2. An appeal under this section must be taken as from an order or a judgment in a civil action.

History. Acts 1969, No. 260, § 19; A.S.A. 1947, § 34-529; Acts 2011, No. 695, § 1.

RESEARCH REFERENCES

ALR.

Adoption of manifest disregard of law standard as nonstatutory ground to review arbitration awards governed by Uniform Arbitration Act (UAA). 14 A.L.R.6th 491.

Case Notes

Appealable Orders.

Order refusing to vacate an arbitration award was tantamount to an order confirming an arbitration award and was therefore appealable under subdivision (a)(3) of this section. ESI Group, Inc. v. Brown, 90 Ark. App. 6, 203 S.W.3d 664 (2005) (decided under prior version of uniform act).

Appellate court overruled the credit card customer's assertion that the appellate court had no jurisdiction to review the denial of the bank's petition and application to confirm the arbitration award against the customer, because the bank was appealing from the denial of its petition to confirm the arbitration award, not from the denial of its motion for summary judgment. MBNA Am. Bank, N.A. v. Blanks, 100 Ark. App. 8, 262 S.W.3d 618 (2007) (decided under prior version of uniform act).

Jurisdiction to hear the appeal of the denial of the motion to compel arbitration was under the rule and statute. Progressive Eldercare Services—Chicot v. Long, 2014 Ark. App. 661, 449 S.W.3d 324 (2014).

Nonappealable Orders.

An order compelling arbitration is not appealable. Chem-Ash, Inc. v. Ark. Power & Light Co., 296 Ark. 83, 751 S.W.2d 353 (1988) (decided under prior version of uniform act).

Cited: HPD, LLC v. Tetra Techs., Inc., 2012 Ark. 408, 424 S.W.3d 304 (2012); Courtyard Gardens Health & Rehab., LLC v. Quarles, 2013 Ark. 228, 428 S.W.3d 437 (2013).

Notes of Decisions
Cited in 19 cases (10 in the last 5 years), 2012–2026 · leading case: HPD, LLC v. Tetra Tech., Inc., 424 S.W.3d 304 (Ark. 2012).
HPD, LLC v. Tetra Tech., Inc., 424 S.W.3d 304 (Ark. 2012). · cites it 2× “TETRA responds that the severability clause, the limitation on the arbitrators’ authority, and the default clause combine to negate the notion that the parties agreed to arbitrate issues of arbitrability.”
Pine Hills Health & Rehab. LLC v. Talley, 546 S.W.3d 492 (Ark. Ct. App. 2018). · cites it 2× “-Civil 2(a)(12); see also Ark. Code Ann. § 16-108-228 (a)(1) (Repl.”
Altice USA, Inc., D/B/A Suddenlink Commc'ns v. Sandra Peterson, 2023 Ark. App. 116 (Ark. Ct. App. 2023). · cites it 2× “Suddenlink unsuccessfully moved to compel arbitration in circuit court, and pursuant to Arkansas Code Annotated section 16-108-228 (Repl. 2016) and Rule 2(a)(12) of the Arkansas Rules of Appellate Procedure–Civil, it now takes this appeal.”
Bhc Pinnacle Pointe Hosp., LLC v. Debra Nelson & Henry Anderson, Jr., Individually, & on Behalf of All Others Similarly Situated, 2020 Ark. 70 (Ark. 2020). · cites it 2× “]” The employees contend that section 16-108-228 does not apply to the present dispute because the Arkansas Uniform Arbitration Act (“AUAA”) does not apply to employer- employee disputes.”
Searcy Healthcare Ctr. LLC v. Murphy, 2013 Ark. 463 (Ark. 2013). · cites it 2× “They are more suited for the appeal of an order granting a motion to compel arbitration.”
BDO Seidman, LLP v. SSW Holding Co., 386 S.W.3d 361 (Ark. 2012). · cites it 2× “On appeal, BDO argues (1) that the circuit court erred in denying arbitration because the claim of fraud in the inducement must be resolved by the arbitrator and not the courts, (2) that arbitration cannot be avoided because of unconsciona-bility, and (3) that all of the claims…”
Innisfree Health & Rehab, LLC; Cent. Arkansas Nursing Centers, Inc.; Nursing Consultants, Inc., D/B/A Prof'l Nursing & Rehab. Servs.; Innisfree Estates, LLC; & Michael S. Morton v. Vicki Titus, as Special Adm'r of the Est. of Helen Gale Gilmore, & on Behalf of the Wrongful Death Beneficiaries of Helen Gale Gilmore, 2021 Ark. App. 403 (Ark. Ct. App. 2021). · cites it 2× “The appellee is Vicki Titus, as special 1 Our jurisdiction to hear the appeal is pursuant to Rule 12(a)(2) of the Arkansas Rules of Appellate Procedure–Civil and Ark. Code Ann. § 16-108-228 (a)(1) (Repl.”
Gibbons v. Anderson, 575 S.W.3d 144 (Ark. Ct. App. 2019). · cites it 2× “2(a)(12) ; Ark. Code Ann. § 16-108-228 (1) (Repl. 2016).”
Altice USA, Inc., D/B/A Suddenlink Commc'ns v. Pam & Jesse Runyan, Parents & Guardians of J.R., an Incapacitated Person, 2023 Ark. App. 124 (Ark. Ct. App. 2023). · cites it 2× “Suddenlink unsuccessfully moved to compel arbitration in circuit court, and pursuant to Arkansas Code Annotated section 16-108-228 (Repl. 2016) and Rule 2(a)(12) of the Arkansas Rules of Appellate Procedure–Civil, it now takes this appeal.”
Altice USA, Inc., D/B/A Suddenlink Commc'ns v. Ronnie Francis & Debbie Francis, 2023 Ark. App. 117 (Ark. Ct. App. 2023). · cites it 2× “Suddenlink unsuccessfully moved to compel arbitration in circuit court, and pursuant to Arkansas Code Annotated section 16-108-228 (Repl. 2016) and Rule 2(a)(12) of the Arkansas Rules of Appellate Procedure–Civil, it now takes this appeal.”
Stipanuk v. Williams, 552 S.W.3d 34 (Ark. Ct. App. 2018). · cites it 2× “Thus, the court found that "[t]he rationale for giving the benefit of a contractual agreement to non-signing entities involved in the operation and control of an enterprise" did not apply.”
Sherwood Nursing & Rehab. Ctr., Inc.; Sherwood Nursing Ctr., Inc.; Cent. Arkansas Nursing Centers, Inc.; David Norsworthy; Michael S. Morton; Kindred Hospice Servs., LLC; Odyssey Healthcare Operating A, Lp, D/B/A Kindred Hospice II v. Susan Cazort, as Special Adm'x of the Est. of Lena Mozelle McGaughey, & on Behalf of the Wrongful Death Beneficiaries of Lena Mozelle McGaughey, 2022 Ark. App. 65 (Ark. Ct. App. 2022). · cites it 2× “Kindred Defendants’ Motion to Adopt and Join the Motion to Compel Arbitration is DENIED because the Kindred Defendants failed to meet their burden of proof that they, as nonsignatories to the arbitration agreement have the right to compel arbitration to the facts of the case.…”
— Ark. Code Ann. § 16-108-228(1) — 1 case
HPD, LLC v. Tetra Tech., Inc., 424 S.W.3d 304 (Ark. 2012). “TETRA responds that the severability clause, the limitation on the arbitrators’ authority, and the default clause combine to negate the notion that the parties agreed to arbitrate issues of arbitrability.”
— Ark. Code Ann. § 16-108-228(a)(3) — 1 case
Unifirst Corp. v. Ludwig Props., Inc., 2015 Ark. App. 694 (Ark. Ct. App. 2015).
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