Mountain Home Flight Service v. Baxter County, et al., No. 12-3000 (8th Cir. 2014)
Annotate this CaseMHFS filed suit against the County, the Commission, and others for interfering with its business operations at the Baxter County Airport. The court concluded that the district court did not err in dismissing MHFS's claims for breach of contract where MHFS did not allege any breach of contract distinct from the breach of the duty to act in good faith; Arkansas law does not recognize a "continuing tort" theory; even if the court were to assume such acts were intentional, MHFS failed to state a claim for intentional interference with its business relationship; the district court correctly dismissed MHFS's civil rights claims for denial of procedural due process where MHFS was not deprived of any property or liberty interest; the district court did not abuse its discretion by declining to exercise supplemental jurisdiction over state law claims; and the district court did not abuse its discretion in denying the motion to amend following its dismissal of the action. Accordingly, the court affirmed the judgment of the district court.
Court Description: Civil case - Civil rights. In action alleging defendants acted in concert to interfere with plaintiff's airport operations, the district court did not err in dismissing plaintiff's breach of contract claim as allegations that defendants breached their duty to act in good faith did not state a breach of contract claim under Arkansas law; Arkansas does not recognize a "continuing tort" theory and the court did not err in dismissing plaintiff's tort claim, as the allegations were either outside the statute of limitations or failed to state a claim; plaintiff's Section 1983 claims failed to articulate a property or liberty deprivation and were properly dismissed; district court did not abuse its discretion by declining to exercise supplemental jurisdiction over state law claims; district court did not abuse its discretion by denying plaintiff's motion to amend following dismissal of the suit.
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