Arkansas Supreme Court Again Holds That Undismissed Pro Se Defendants Preclude Appellate Review
"Rule 54(b) has caused problems for lawyers and judges alike" is the reporter's modest comment in the notes to the 2001 amendment. Wilson & Associates, Inc. v. Vimy Ridge Municipal Water Improvement District 139, illustrates the problem of failing to obtain dismissals for all defendants in an action, especially "John Doe" defendants. The water improvement district Wilkins and several other defendants, including "John Doe(s) and Jane Doe(s)," for delinquent assessments. The trial court granted summary judgment as to Wilkins. The record did not dispose of several of the defendants including the John Doe defendants. The Arkansas Supreme Court dismissed for lack of a final order: "This Court has specifically held that where John Doe claims have not been determined, dismissal on the basis of Rule 54(b) is appropriate."
