Joe Capps, Raymond W. Zroback, & Patricia Zroback

Summary

The court affirmed dismissal of the plaintiffs' claims seeking monetary relief and return of patronage capital because the claims arose under Arkansas's public-utility statutes and fell within the Arkansas Public Service Commission's primary and exclusive jurisdiction. The court rejected the argument that relabeling the claims as contract, tort, property, fiduciary-duty, or unjust-enrichment claims converted them into private-right disputes outside the Commission's authority. It also held that the Missouri plaintiffs' claims were within the Commission's jurisdiction because they were based on alleged violations of Arkansas law rather than Missouri law.