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Don Plumlee v. Victoria Marie Sumerix and Mynor Ramos

2026-08-26

Summary

Holding. The court ordered rebriefing because the appellant's brief failed to comply with Arkansas Supreme Court Rule 4-2(a) in multiple respects, and the court cannot reach the merits of any arguments until a compliant substituted brief is filed within fifteen days.

Don Plumlee appealed a circuit court order in a dispute with Victoria Marie Sumerix and Mynor Ramos. The Arkansas Court of Appeals found that Plumlee's appellate brief contained multiple procedural deficiencies that prevented the court from addressing the substance of his claims. Specifically, his brief listed five points on appeal but then discussed twenty-four separate issues in the argument section without properly organizing them under numbered subheadings, failed to include the required standard of review for each issue, injected arguments into the statement of facts rather than keeping them separate, and omitted essential trial testimony and procedural information necessary to understand the case.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Compliance with appellate briefing rules and structure
  • Proper organization of points on appeal with corresponding argument subheadings
  • Requirement to state standard of review for each issue
  • Adequacy of statement of case and facts with necessary trial information

Procedural posture

The appellant appealed from a Sebastian County Circuit Court order resolving his complaint against the appellees.

Authorities cited

Opinion

majority opinion

Cite as 2026 Ark. App. 375

ARKANSAS COURT OF APPEALS

DIVISION I

No. CV-25-270

Opinion Delivered August 26, 2026

DON PLUMLEE APPEAL FROM THE SEBASTIAN COUNTY

APPELLANT CIRCUIT COURT, FORT SMITH

DISTRICT

V. [NO. 66FCV-24-1054]

VICTORIA MARIE SUMERIX AND HONORABLE GREG MAGNESS, JUDGE MYNOR RAMOS

APPELLEES

REBRIEFING ORDERED

KENNETH S. HIXSON, Judge

Pro se appellant Don Plumlee appeals after the Sebastian County Circuit Court filed

an order resolving his complaint against appellees Victoria Marie Sumerix and Mynor

Ramos. On appeal, Mr. Plumlee lists several points on appeal. However, because of briefing

deficiencies, we are unable to reach the merits of any of his arguments at this time and must

order rebriefing.

Arkansas Supreme Court Rule 4-2(a) states the following in relevant part:

(3) Points on appeal. The appellant shall list and separately number, concisely and

without argument, the points relied upon for a reversal of the judgment or decree.

The appellee must follow the same sequence and arrangement of points as contained

in the appellant’s brief and may then state additional points. Either party may insert

under any point not more than two citations which the party considers the principal

authorities on that point.

(6) Statement of the case and the facts. The appellant’s brief shall contain a concise

statement of the case and the facts without argument. The statement shall identify and discuss

all material factual and procedural information contained in the record on appeal. Information

in the appellate record is material if the information is essential to understand the case and to

decide the issues on appeal. All material information must be supported by citations to

the pages of the appellate record where the information can be found.

(7) Argument. Arguments shall be presented under subheadings numbered to correspond to

the outline of points to be relied upon. For each issue, the applicable standard of review shall

be concisely stated at the beginning of the discussion of the issue. Citations of decisions of

the Arkansas Supreme Court and Court of Appeals must be from the official reports,

and all citations to both official and unofficial reports shall follow the format

prescribed in Rule 5-2. All citations of decisions of any other court must state the

style of the case and cite the official reporter (including a regional reporter so

designated by the issuing court) in which the case is found. If the case is also reported

by unofficial publishers, including an unofficial electronic database, one of these

should also be cited. Reference in the argument portion of the parties’ briefs to

material found in the appellate record shall be followed by a reference to the page

number of the appellate record at which such material may be found.

(Emphasis added.)

Mr. Plumlee’s brief fails to comply with these rules. Mr. Plumlee lists five “POINTS

ON APPEAL” on page 3 of his appellate brief but subsequently discusses twenty-four

separate “ISSUES” in the argument section of his brief. In other words, appellant’s

arguments are not presented under subheadings numbered to correspond to the outline of

points to be relied on as required. See Ark. Sup. Ct. R. 4-2(a)(3), (7); Mf v. Lindsey, 2026 Ark.

App. 214; Sowell v. Evergreen Packaging, LLC, 2024 Ark. App. 498. Moreover, no standard of

review has been noted at the beginning of the discussion of the issue as required. Id.

Additionally, appellant has injected arguments throughout his statement of the case and fails

to discuss the material procedural and factual information essential to understand this case

on appeal, including a discussion of the relevant testimony presented at trial. See Ark. Sup.

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Ct. R. 4-2(a)(6); Mf, supra; Sowell, supra. The requirement for a proper statement of the case

is not only for the benefit of this court to understand the case and facts, but the failure to

include necessary facts can also limit appellant’s requested review of any opinion offered by

this court. Arkansas Supreme Court Rule 2-3(h) states, “In no case will a rehearing petition

be granted when it is based upon any fact thought to have been overlooked by the Court,

unless reference has been clearly made to it in the statement of the case and the facts

prescribed by Rule 4-2.”

Finally, we note that Mr. Plumlee filed a lengthy document with the circuit court

discussing his “ISSUES FOR APPELLATE REVIEW” and his “OBJECTIONS” to the

circuit court’s order after he had filed his notice of appeal. He makes references to this

document and the attached exhibits throughout the argument section of his brief. To the

extent Mr. Plumlee intended this document to serve as a second appellate brief in

contravention of our rules, we cannot consider it. See Ark. Sup. Ct. R. 4-7. Moreover, we

cannot consider any additional evidence offered by appellant that was not considered by the

circuit court in making its decision. See Qualls v. Ferritor, 329 Ark. 235, 947 S.W.2d 10

(1997); Rochelle v. Piles, 244 Ark. 606, 427 S.W.2d 10 (1968).

We may raise the issue of briefing deficiencies on our own, at any time. Mf, supra.

The mandatory language of Rule 4-2 prevents us from overlooking appellant’s failure to

comply with the rules. Accordingly, we order appellant to file a substituted brief curing any

deficiencies within fifteen days from the date of this opinion. See Ark. Sup. Ct. R. 4-4(g)(2)(C). The list of deficiencies noted is not exhaustive, and we encourage appellant to

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carefully examine our rules before resubmitting his brief. Once the substituted brief is filed,

appellees will have fifteen days to submit their responsive briefs. If appellant fails to file a

compliant brief within the prescribed time, the judgment may be affirmed or the appeal

dismissed for noncompliance with the rule. Id.

Rebriefing ordered.

ABRAMSON and THYER, JJ., agree.

Don Plumlee, pro se appellant.

One brief only.

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