Supreme Court of Arkansas
John R. Lambert, Ii v. Lq Management, L.L.C.
March 14, 20132013 Ark. LEXIS 133
Summary
The court answered a certified question by holding that Arkansas Code Annotated section 16-118-107 did not revive an individual common-law retaliation claim abolished by section 11-9-107. Because section 11-9-107 specifically makes the workers' compensation remedies exclusive and expressly annulled contrary common-law remedies, the general civil-liability statute could not provide an additional recovery. The court relied on the plain meaning of the statutes, the specific-over-general rule, and strict construction of workers' compensation statutes.