Retention of Trial-Court Jurisdiction Over Collateral Postmandate Motions

Introduction

Donnell and Marilyn Bauer (“the Bauers”) sold real property to Jesse Lee Beamon Jr. and Mary A. Beamon (“the Beamons”) in Crawford County, Arkansas. After trial, the circuit court denied the Beamons’ equitable rescission claim but awarded them damages for breach of contract and later granted them attorney’s fees. The Bauers appealed; this Court reversed the breach-of-contract award, affirmed the denial of rescission, and vacated the attorney-fee ruling for lack of jurisdiction. When the Beamons sought payment on the fee judgment, the Bauers filed two new motions in the trial court: one for their own attorney’s fees and costs as the newly prevailing party, and one under Arkansas Rule of Civil Procedure 60(c)(4) to set aside the Beamons’ fee judgment for fraud. The trial court held it lacked jurisdiction to consider either motion. The Bauers appealed that ruling.

Summary of the Judgment

In Bauer v. Beamon (2025 Ark. 16), the Supreme Court of Arkansas held that the trial court erroneously concluded it lacked jurisdiction to consider the Bauers’ two postmandate motions:

A motion for attorney’s fees as the prevailing party;
A Rule 60(c)(4) motion to set aside the Beamons’ attorney-fee judgment for fraud.

The Court confirmed that under the mandate rule, a trial court must follow the appellate mandate but retains authority over collateral and supplemental matters not addressed in the mandate. Attorney’s-fee awards are collateral, and Rule 60(c)(4) post-judgment relief lies within the trial court’s continuing jurisdiction. Accordingly, the Supreme Court reversed the circuit court’s jurisdictional ruling and remanded for decision on the merits of both motions.

Analysis

Precedents Cited

Dye v. Diamante, 2017 Ark. 37, 509 S.W.3d 643
Established that the appellate mandate binds the lower court, which “has no power or authority to deviate from the mandate.”
Ingle v. Arkansas Department of Human Services, 2014 Ark. 471, 449 S.W.3d 283
Confirmed that the mandate rule creates a binding law-of-the-case for issues decided on appeal.
Wal-Mart Stores, Inc. v. Regions Bank Trust Department, 356 Ark. 494, 156 S.W.3d 249 (2004)
Reiterated that a trial court’s jurisdiction post-mandate is limited by the appellate court’s directions.
Alexander v. First National Bank of Fort Smith, 278 Ark. 406, 646 S.W.2d 684 (1983)
Held that awards of attorney’s fees are “collateral” matters and remain within the trial court’s control even after an appeal is docketed.
Harold Ives Trucking Co. v. Pro Transportation, Inc., 341 Ark. 735, 19 S.W.3d 600 (2000)
Further confirmed that attorney’s-fee awards are collateral to the main judgment.
Davis v. Davis, 291 Ark. 473, 725 S.W.2d 845 (1987)
Held that a trial court may grant postmandate relief under Rule 60(c)(4) to set aside a judgment for fraud.

Legal Reasoning

The Court’s reasoning rests on two complementary doctrines:

Mandate Rule and Law-of-the-Case Doctrine. Once the Supreme Court issues its mandate, the trial court must execute the appellate judgment faithfully and cannot reopen or vary issues decided on appeal. But the scope of the mandate governs only the issues addressed by the appellate opinion.
Residual Jurisdiction Over Collateral Matters. Matters collateral to the judgment—like attorney’s fees—and post-judgment motions under Rule 60(c) remain within the trial court’s authority unless explicitly foreclosed by the mandate. Here, the mandate reversed the substantive damages award and vacated the attorney-fee award to the Beamons but said nothing about the Bauers’ right to seek fees or to move under Rule 60(c)(4).

Because neither collateral attorney’s-fee motions nor Rule 60(c) motions were decided in the first appeal, the circuit court retained jurisdiction to hear them.

Impact

This decision clarifies that under Arkansas law:

Appellate courts wishing to foreclose new collateral issues must explicitly include them in the mandate.
Trial courts may proceed with postmandate motions for attorney’s fees and motions for relief from judgment under Rule 60(c), even if an appeal is pending or has been decided.
The decision safeguards parties’ ability to enforce or contest fee awards and to seek relief from judgment for fraud without endless jurisdictional disputes.

Future litigants will rely on this ruling to ensure that collateral or supplemental motions are timely heard, and appellate courts will be cautious to define their mandates narrowly to avoid unintended reopenings of issues.

Complex Concepts Simplified

Mandate Rule: The binding instruction from an appellate court that the trial court must follow exactly; it cannot ignore or contradict that instruction.
Law-of-the-Case Doctrine: Issues decided on appeal cannot be relitigated in the trial court; they become settled for the remainder of the case.
Collateral Matters: Secondary issues, like awarding attorney’s fees, that are related to—but distinct from—the core judgment.
Arkansas Rule of Civil Procedure 60(c)(4): Allows a party to ask the trial court to vacate or modify a judgment if it was obtained through fraud, even after an appeal.

Conclusion

Bauer v. Beamon (2025 Ark. 16) establishes that trial courts in Arkansas retain jurisdiction to decide collateral attorney’s-fee motions and post-judgment Rule 60(c) motions even after an appellate mandate issues, so long as those matters were not resolved on appeal. By reaffirming the boundary between core mandate issues and residual trial-court powers, the decision promotes finality in core judgments while preserving access to justice for ancillary relief. Trial judges and appellate courts alike must now carefully delineate the reach of their mandates to prevent confusion over jurisdiction in postmandate proceedings.