Arkansas Code Annotated

Ark. Code Ann. § 4-2-107 (2026)

Goods to be severed from realty — Recording

✓ current as of May 2026
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  1. A contract for the sale of minerals or the like (including oil and gas) or a structure or its materials to be removed from realty is a contract for the sale of goods within this chapter if they are to be severed by the seller but until severance a purported present sale thereof which is not effective as a transfer of an interest in land is effective only as a contract to sell.
  2. A contract for the sale apart from the land of growing crops or other things attached to realty and capable of severance without material harm thereto but not described in subsection (1) or of timber to be cut is a contract for the sale of goods within this chapter whether the subject matter is to be severed by the buyer or by the seller even though it forms part of the realty at the time of contracting, and the parties can by identification effect a present sale before severance.
  3. The provisions of this section are subject to any third party rights provided by the law relating to realty records, and the contract for sale may be executed and recorded as a document transferring an interest in land, and shall then constitute notice to third parties of the buyer's rights under the contract for sale.

History. Acts 1961, No. 185, § 2-107; 1973, No. 116, § 3; A.S.A. 1947, § 85-2-107.

Publisher's Notes. Acts 1973, No. 116, § 1, amended or reenacted the provisions of Acts 1961, No. 185, Art. 9, as amended (former Chapter 9 of this title).

Acts 1973, No. 116, § 5, provided that all transactions which were subject to the provisions of Acts 1961, No. 185, Art. 9, as amended (former Chapter 9 of this title), and which were executed prior to January 1, 1974, would be governed by Acts 1961, No. 185, Art. 9, as amended and in effect prior to January 1, 1974.

Case Notes

Mineral Interests.

Errors in earlier decree regarding royalties and conveyance of mineral interests, which decree was not appealed, could not be relitigated or corrected by subsequent purchasers of those mineral interests. Phelps v. Justiss Oil Co., 291 Ark. 538, 726 S.W.2d 662 (1987).

Statute of Frauds.

Oral contract between the company and the contractor for excavation work was for the sale of services, not goods or an interest in land, and therefore was not subject to the statute of frauds; the company promised to pay the contractor to remove the dirt; thus, the contractor was the seller, the company the buyer, and services, not dirt, were sold. Hodges v. John F. Jenkins Contr., Inc., 98 Ark. App. 125, 252 S.W.3d 152 (2007).

Timber Sales.

The UCC is made applicable to timber sales by this section. Davis v. Kolb, 263 Ark. 158, 563 S.W.2d 438 (1978).

Cited: In re Estate of Spann, 257 Ark. 857, 520 S.W.2d 286 (1975); Herrick v. Robinson, 267 Ark. 576, 595 S.W.2d 637 (1980); Williams v. J.W. Black Lumber Co., 275 Ark. 144, 628 S.W.2d 13 (1982); Montwood Corp. v. Hot Springs Theme Park Corp., 766 F.2d 359 (8th Cir. 1985).

Part 2 — Form, Formation, and Readjustment of Contract

Publisher's Notes. For Comments regarding the Uniform Commercial Code, see Commentaries Volume A.

Effective Dates. Acts 2001, No. 1439, § 23: July 1, 2001. Emergency clause provided: “It is hereby found and determined by the General Assembly that the present Article 9 of the Uniform Commercial Code which exists in all fifty states, the District of Columbia, and Puerto Rico is obsolescent and is in need of significant expansion to cover new categories of collateral, to promote electronic filing, to reduce duplicate filing, and to resolve conflicting case law. The revisions contained in this Act will bring greater certainty to financing transactions, and will reduce both their cost and the cost of credit. Because current Article 9 is uniform throughout the United States, it becomes essential that the effective date for the substantial revisions contemplated by this Act be the same in every state. If Arkansas and all of the other states and territories do not act in concert and enact a common effective date, severe complications will arise. For example, the proper place to perfect a security interest depends on the law of the state where the issue is litigated. Therefore, the rules for filing must be uniform at all times. Because the several states are proposing that the revised Article 9 become effective on July 1, 2001 an emergency is hereby declared to exist and this Act being necessary for the preservation of the public peace, health, and safety shall be in full force and effect on July 1, 2001.”

Research References

ALR.

Conditional acceptance: Conversion to rejection and counteroffer under UCC § 2-207(1). 22 A.L.R.4th 939.

Promissory estoppel as basis for avoidance of UCC statute of frauds (UCC § 2-201). 29 A.L.R.4th 1006.

“Specially manufactured goods” statute of frauds exception in UCC § 2-201(3)(a). 45 A.L.R.4th 1126.

Am. Jur. 67 Am. Jur. 2d, Sales, § 111 et seq.

C.J.S. 77A C.J.S., Sales, § 26 et seq.

Notes of Decisions
Cited in 4 cases (1 in the last 5 years), 1996–2025 · leading case: Lenape Resources Corp. v. Tennessee Gas Pipeline Co., 925 S.W.2d 565 (Tex. 1996).
Lenape Resources Corp. v. Tennessee Gas Pipeline Co., 925 S.W.2d 565 (Tex. 1996). “§ 47-2107; Ark.Code Ann. § 4-2-107; Cal.Com.Code § 2107; Colo.”
Buford v. Alderson, 965 S.W.2d 802 (Ark. Ct. App. 1998). · cites it 2× “We note that no argument has been made concerning the application or effect of Ark. Code Ann. § 4-2-107 (Repl. 1991), or of Ark.”
Hodges v. John F. Jenkins Contracting, Inc., 252 S.W.3d 152 (Ark. Ct. App. 2007). · cites it 4× “If Jenkins had agreed to pay Hodges for the dirt, this transaction would have been subject to the Uniform Commercial Code’s statute of frauds, because Jenkins was to sever the dirt.”
Church on the Rock - Texarkana v. Ace Signs of Arkansas, LLC, 2025 Ark. App. 35 (Ark. Ct. App. 2025). ““Goods” means all things (including specially manufactured goods) which are moveable at the time of identification to the contract for sale other than the money in which the price is to be paid, investment securities (Chapter 8 of this title) and things in action. “Goods” also…”
— Ark. Code Ann. § 4-2-107(1) — 1 case
Hodges v. John F. Jenkins Contracting, Inc., 252 S.W.3d 152 (Ark. Ct. App. 2007). “If Jenkins had agreed to pay Hodges for the dirt, this transaction would have been subject to the Uniform Commercial Code’s statute of frauds, because Jenkins was to sever the dirt.”
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